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Sponsorships and Speaking Engagements | 2-3 November 2023
PIAC Tax Conference - Fund Investments: ECI, FDAP, FIRPTA and other U.S. Tax Considerations for Canadian Pension Funds
Tax partner Cristina Arumi and Tax associate Elizabeth Adams will be participating during PIAC’s Tax Conference in a session titled Fund Investments: ECI, FDAP, FIRPTA and other U.S. Tax Considerations for Canadian Pension Funds on 2 November at 3:30 p.m.
This session will provide a technical overview of the key U.S. tax considerations for Canadian pension funds investing in U.S. funds. The panelists will describe and discuss common fund structures and US tax concepts that influence the US fund structures and are of particular interest to Canadian pension fund investors – including dispositions in the secondaries market and contract provisions affecting tax that are likely to be most important depending on the size of the deal and the vintage of the fund. Attendees of this session will come away with greater insights into the tax rules most commonly applicable to Canadian pension funds, including the U.S. trade or business and effectively connected income (ECI) rules, the U.S. taxation of investment income, and exceptions specific to foreign pension funds (including under Section 892 and the qualified foreign pension fund (QFPF) rules of the Foreign Investment in Real Property Tax Act (FIRPTA)).
For the full program and to register click HERE.
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