Recent events have driven financial institutions around the world to attempt to strengthen their capital positions in order to better withstand the current economic downturn. As if the current economic environment was not challenging enough for these institutions, a popular vehicle used by Canadian banks and life insurers for raising capital was inadvertently caught by the special regime of tax rules applicable to "specified investment flow-through" trusts and partnerships. Co-authored with Chris Van Loan and originally published in Innovative Financing, Vol. II, No. 4, P. 113, 2009.