conclusions...

1. The Canadian withholding tax on FTE's will increase from 15% to 41.5% for U.S. investors (beginning in 2011 for existing FTE's).

Will these companies change their structure?

2. FTE trusts will no longer be able to deduct distributions. This means that they will pay an additional 21% tax on earnings. For example, Canetic Resources Trust (CNE) has a payout ratio of about 75%. This will reduce overall earnings by about 16%.

Will these companies continue paying their current level of distributions?