I read that one the biggest reasons if not the main reason for the reorganization of PBG and PBN and PBG spinning off it's shares in PBN's to it's shareholders before the end of 2012, was due to tax implications for US shareholders.  Canadian shareholders will not have to pay any tax, but American shareholders will.  The shares US investors receive will be treated as a dividend, presently tax at a rate of 15% and scheduled to go to regular tax rates in 2013, effectivly doubling the tax for most investors.