Tax considerations often influence how these opportunities are pursued. From this perspective, foreign fund managers should be focused on how to structure Canadian investments to minimize Canadian withholding and income tax on investment returns as well as structuring funds, including feeder funds, in a tax-efficient manner to raise capital from Canadian taxable and non-taxable investors. In addition, an offshore foreign fund that engages Canadian service providers will need to comply with the Canadian safe harbour rules in order to minimize the fund’s Canadian tax exposure.