France: Comparability Criteria for WHT Exemptions of Collective Investment Funds
A recent update published by the French tax authorities (FTA) on the 12th of August 2020 offers revised guidelines as to the requirements non-European Union (EU) collective investment funds must meet, in order to be entitled to withholding tax exemptions on French source dividends, pursuant to Article 119 bis, 2 of the French Tax Code.
US Withholding Tax Refunds from Canadian Pooled Fund Investments
By guest author Max Reed. Max is a cross-border tax lawyer and the founding partner of Polaris Tax Council Canada. WTax partners with Polaris Tax Council in recovering US withholding tax for investors of Canadian pooled funds.
UPDATE: Dividend Withholding Tax: What Happens Post the Brexit Transition Period?
Earlier this year, WTax outlined some of the withholding tax implications of Brexit (click here). This article explores the latest developments, on how the UK’s official withdrawal from the EU will affect the withholding taxes levied on UK-domiciled funds, once the transitional period ends at the end of 2020. This is in light of the European Commission’s announcement on the 7th of July 2020, in which it was confirmed and stakeholders were informed that as from the end of the transition period (31 December 2020), the EU rules in the field of asset management — in particular Directive...
Know More About International Withholding Tax Recovery
There is a great deal to be gained from understanding the inner workings of international withholding tax (WHT) recovery – especially when it comes to dividend income. Institutional investment firms stand to increase their clients’ ROI on foreign investments by up to 0.5% by simply unlocking the various dividend WHT reclaim methodologies. If you want to know more about international withholding tax recovery, this article will provide a good foundation.
Withholding Tax Refunds: Unlocking 0.5% Increase in Fund Performance
While global markets continue to recover from the COVID-19 pandemic and uncertainty still lingers around the immediate future of dividends, investment firms should be looking for sound and innovative ways to boost investment performance.
To Accrue or Not to Accrue — That is the Question
Should you be accruing for withholding tax recoveries on foreign investment income or should these recoveries should rather be accounted for on a cash basis? In the accounting world, the eternal goal is to ensure that financial records accurately reflect the financial position of a particular entity at a point in time. This generally means accounting for transactions when they occur as opposed to when the cash implications are felt.
The Race to Withholding Tax Recovery – Statutes of Limitations
Withholding tax recovery opportunities unfortunately don’t exist forever. Every investment market has a statute of limitation for withholding tax (WHT) recovery claims to be filed. This means that each claim has an expiry date and the claims must be filed before this date, to ensure that the recovery is not lost.
Tax Exemption for CITs
Collective Investment Trusts (CITs) or group trusts as they are commonly referred to, are addressed in Internal Revenue Service (IRS) Revenue Ruling 81-100 (as modified by Revenue Ruling 2004-67, Revenue Ruling 2011-1 and Revenue Ruling 2014-24). The IRS provided special dispensation for CITs in the form of exemption from income tax to ensure that these structures can be used to pool assets of various qualified retirement plans, individual retirement accounts and other similar plans without creating unnecessary income tax obligations. The goal is to ensure that pension-related money and the...