In 2013-0496831R3, the CRA ruled that an Irish Common Contractual Fund (CCF) was a fully transparent unincorporated body, such that each investor in the CCF was considered to hold a direct undivided co-ownership interest in the underlying properties of the CCF.  Investors resident in different foreign countries would subscribe for different “Classes of Unit” in the CCF; this would accommodate different entitlements to the CCF’s underlying income having regard to different withholding tax rates.  In other words, the foreign investors in the CCF could assert different treaty benefits – under tax treaties with their home country – in respect of their direct share of income and gains realized by the CCF.  Additional rulings were provided reinforcing the fully transparent nature of the CCF.