Crius Energy Trust offering uses a double-hybrid structure
8 October 2012 - 1:02pm
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.