Any structuring of investments by a Latin American investor into Canada through the U.S., or any acquisition of a U.S. business which either operates a Canadian business or which receives Canadian-sourced payments, and any decision to acquire a Canadian business or to expand Canadian operations where business arrangements and particularly intercompany funding result in a U.S. resident receiving Canadian-sourced cash flows should include a review of how the Limitation on Benefits (“LOB”) rules in the recently revised Canada-U.S. Income Tax Convention (the “Treaty”) may apply.