2006 Ruling 2004-0106101R3 - Class of German Arrangement & Treaty Benefits -- summary under Subsection 104(1)

Ruling that an open-end real estate fund established under the Investment Companies Act (Germany) (and to be continued under the Investment Act (Germany)) would be treated as an inter vivos trust that was not a personal trust for purposes of the Act in respect of its proposed investments in a Canadian partnership. The fund had a German manager and was required to have its real estate assets held by the manager and was deemed under the Investment Act to be an estate.