These funds would retain and reinvest earnings rather than pay dividends, thereby affording substantial tax advantages to United States investors”particularly those in high income tax brackets, who could forego current income in the expectation of capital gains. The major requirements imposed upon these non-resident owned (NRO) companies were (and still are) that they be incorporated and operated in Canada but be at least 95 per cent owned by non-Canadians. Securities and cash owned by the fund were required by the SEC to be kept in the United States. At the end of 1959, the combined total assets of the nine NRO companies then in existence amounted to $396 million. What are the various tax advantages which these companies can offer? 1.

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