Trusts are used in ever more financial transactions and securities offering in Canada, the U.S. and foreign jurisdictions. Our experienced tax and trusts lawyers are among the most knowledgeable in this expanding field. Working with our corporate and structured finance lawyers, we regularly advise on the numerous, complex tax and non-tax issues that arise in the structuring of business trusts, including with respect to asset securitizations, income funds, REITS and structured product offerings. We are regularly consulted by industry associations on the legal and regulatory issues related to the use of business trusts.
Below is a short list of matters involving business trusts on which we have acted recently:
- Establishment of CMBS real estate investment trust with TIAA-CREF and restructuring of holdings of New York and Washington properties (approximately $160 million);
- Formation of $200 million real estate investment partnership for RioCan Real Estate Investment Trust;
- Initial public offering of $130 million of 3.399% Receivables-Backed Notes, Series 2003-1, Class A and $60 million of 3.805% Receivables-Backed Notes, Series 2003-2, Class A of CFI Trust;
- $1.133 billion credit card securitization program for Capital One;
- Initial public offering of $1.13 billion of units of Pro-AMS Trust, the largest structured product equity offering ever in Canada.
