4 October 2010 Internal T.I. 2008-0289461I7 - Netherlands Antilles private foundation -- summary under Corporation

Although a Netherlands Antilles private foundation had separate legal personality (including a separate legal entity clause in the governing legislation) and capacity to acquire rights and liabilities (with no beneficiary liability), CRA nonetheless considered it to be a trust rather than a corporation given that it did not issue shares, the beneficiaries did not pay for their interests in the foundation, they could not transfer their beneficial interests and they did not have a right to participate in any decisions of the foundation. Although it was still quite dissimilar to a common law trust, it was sufficient that it was somewhat similar to a civil law trust.