Our Thinking

Insights and big ideas from CIBC Mellon and BNY Mellon, designed to help institutional investors in Canada navigate today's complex market and regulatory environment.

Five Tax Considerations for Global Institutional Investors

September 2019

As global institutional investors navigate international markets in pursuit of their investment goals, the pursuit of appropriate tax treatment and the effective execution of tax filing, reclaim and other activities is a key aspect of investment operations. After all, investors are keen to avoid leaving money on the table, and to ensure they meet the necessary requirements from local authorities as they invest into target markets.

Canada Enacts the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting

July 2019

Canada’s Department of Finance announced that the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (also known as the Multilateral Instrument, or MLI) sponsored by the Organisation for Economic Co-operation and Development (OECD), has been enacted into law in Canada.

Fair Value Pricing

July 2019

When the price of a security isn’t readily available, fund managers are able to estimate the value of a security within a fund. This process is called fair value pricing or fair valuation.

Foreign Account Tax Compliance Act (FATCA)

July 2019

CIBC Mellon and many of its clients are required to take action by the U.S. Department of the Treasury, U.S. Internal Revenue Service (IRS) and the Canadian government (through the legislation introducing the Canada-U.S. Intergovernmental Agreement) (the "IGA") with respect to implementing the provisions of the Foreign Account Tax Compliance Act (FATCA).

New Proposed Regulations for Withholding on Transfers of Certain Partnership Interests

June 2019

The U.S. Treasury Department (Treasury) and the U.S. Internal Revenue Service (IRS) issued proposed regulations with guidance on how to apply withholding tax under U.S. Internal Revenue Code (IRC) Section 1446(f).