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Personal Canadian Trusts should be classified as Financial Institutions under Canadian IGA. And that's how: the Canadian IGA defines “financial institution” to mean a custodial institution, a depository institution, an investment entity, or a specified insurance company. In defining the term “equity interest,” the Canadian IGA explicitly refers to “a trust that is a financial institution.” Furthermore, the Canadian IGA defines “entity” to mean “a legal person or a legal arrangement such as a trust.” Why would trusts be directly referred to in these definitions if they were not subject to FATCA under the Canadian IGA? If the US Treasury had intended to exclude trusts from the definition of “financial institution,” it could have easily done so by omitting the references to trusts in the definitions of “equity interest” and “entity.” Statutory construction principles provide that interpretations that would render unnecessary other provisions or text of a statute or that would defeat the statute’s policy must be avoided. The Canadian implementing legislation accomplishes precisely that by reading all personal trusts out of the Canadian IGA through its restriction on the definition of a financial institution. Also note the omission of annex II(iv)(a) of the Model 1a IGA from the Canadian IGA. That provision creates an exclusion from FATCA for trusteed-documented trusts, or trusts with certain financial institutions as trustees that report the information required under an IGA on their behalf. This omission suggests that the United States intends to treat certain Canadian trusts as financial institutions subject to FATCA under the Canadian IGA.