Meranex -- summary under Foreign Asset Income Funds and LPs
Summary Under
Tax Topics - Public Transactions - Offerings - REIT, Trust and LP Offerings - Foreign Asset Income Funds and LPsIPO of Meranex Energy Trust: Canadian-listed mutual fund trust holding US oil and gas business

A TSX-listed mutual fund trust ("Meranex"), through a Canadian Holdco, will hold a US Opco which will carry on a US oil and gas business, with the internal interest-bearing debt owing by US Opco directly to the Canadian Trust. Structure and tax disclosure are essentially identical to Argent Energy.