15 July 2010 Internal T.I. 2010-0353701I7 - Classification foreign entity - Trust Enterprise -- summary under Subsection 104(1)

Ruling that a Liechstenstein Trust Enterprise would be a trust rather than a corporation. Although it had centralized control, continuity of management and existence, issuance of transferable coupons which might be assimilated to shares, limited liability of coupon holders and legal personality and the ownership of assets, on the other hand it had limited objects, beneficiaries who were not entitled to vote and who did not pay for their interest and who could be liable if they enriched themselves, the application to the entity of rules of equity and references to it as a trust under the Liechtenstein law.