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Managing Canadian investment entities in the U.S.

Author(s): Matias Milet

Apr 30, 2016

Investment entities in the United States that happen to reside in Canada now have detailed guidance for determining their status under the Foreign Account Tax Compliance Act (FATCA). The guidance notes contain provisions for the reporting and non-reporting of eligible Canadian investment entities.

This article, written by Osler lawyer Matias Milet in the Taxation group, also examines the Canada-U.S. intergovernmental agreement (IGA), the overall effect of FATCA on Canada, and the interaction of the Canadian IGA and Income Tax Act. While informative and detailed, Matias’ article does raise a number of questions regarding the varying scope of terms across the different Canadian regulatory bodies.
 

DOWNLOAD PDF: FATCA and Canadian Investment Entities


Matias thanks Nigel Johnston, Jennifer Lee, Grace Pereira, and Paul Seraganian, who reviewed and commented on a draft of the article. Special thanks to his colleague Sharon Ford for her input.