Slate U.S. Opportunity (No. 2) Realty Trust is structured as a cross-border mutual fund without an initial listing

The Slate U.S. Opportunity (No. 2) Realty Trust proposes to invest in US real estate through an Ontario "holding company" LP and a Delaware "grandchild" subsidiary LP, both of which will elect to be corporations for US purposes.  The offered units do not appear to be intended to be listed - but the offering contemplates  a listing of the  units (or an exchange of the units) by September 30, 2018 or an asset sale by them.  In order that the Trust can in the meantime qualify as an open-end unit trust for Canadian tax purposes, there is a technical retraction right, but one which likely is not commercially meaningful.

Neal Armstrong.  Summary of preliminary prospectus for Slate U.S. Opportunity (No. 2) Realty Trust offering under Foreign Asset Income Funds and LPs.