Crius Energy Trust offering uses a double-hybrid structure

Crius Energy Trust, which will be a listed Canadian mutual fund trust, proposes to elect for US purposes to be a partnership.  It will indirectly invest in an LLC (carrying on an energy distribution business in the U.S.) which will be a partnership for US purposes but a US corporate subsidiary for Canadian purposes.  The US anti-inversion rules are expected not to apply as it will initially acquire only a 1/3 interest in the LLC.

Neal Armstrong.  Summary of Crius Energy Trust preliminary prospectus under Foreign Asset Income Funds and LPs.