Financial structure and investment vehicle enabling foreign persons to invest in U.S. based oil, gas and natural gas resource producing properties and potential producing properties in an optimal tax structure

摘要

The various embodiments of the present invention provide a method for providing a financial structure and investment vehicle that enables foreign persons, Canadian Income Trusts and United States (U.S.) based investors to invest in U.S. based real property interests including oil, gas and other natural resource producing properties or potential producing properties in an optimal tax structure. The income stream received from the investments is recategorized as a production payment and taxed at the specific treaty withholding tax rate on interest on real property mortgages between the U.S. and resident country of Foreign Person or Canadian Income Trust.