When FATCA was originally announced, the extent of its application was unclear for many funds. Since then, certain governments have signed Intergovernmental Agreements (IGAs) with the IRS, and more are due to enter into agreements. While the US-Canada IGA and Canada’s implementing legislation have yet to be published, with the US regulations finalized, the application of FATCA is now clearer. Broadly, all funds controlled and managed in Canada will be mandated to comply regardless of their investment or investor base.
Please speak to your KPMG contact or one of our FATCA advisors for further information or advice in respect of the legislation and the impact for you.