No matter what opportunity a foreign fund may pursue in Canada, it is prudent for the fund to do so without risking carrying on business in Canada. If a foreign fund was considered to carry on business in Canada, profits from that business (including interest, dividends, fees, and trading gains) would be subject to Canadian income tax. The phrase “carrying on business” in Canada is broadly defined and the concern is that foreign funds risk carrying on business in Canada by virtue of receiving services from Canadian-resident service providers (such as investment advisors, managers, dealers) or exerting influence over such Canadian-resident service providers. Fortunately, the Canadian safe harbour rules specifically address this tax risk.