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DFA Case Decision: Potential Impacts for U.S. and Canadian Investment Funds

Deloitte Dbriefs | Investment Management

Start date and time

April 24, 2014 2:00 PM

End date and time

April 24, 2014 3:00 PM

Time zone:

(GMT-05:00) Eastern Time (US & Canada)

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Host: Baruch Cohen, Partner - Deloitte Tax LLP
1 Intermediate CPE Credit: Taxes

On April 10, 2014, the European Court of Justice ruled on the Emerging Markets Series of DFA Investment Trust Company case (C-190/12). What are the consequences for U.S. and Canadian investment funds when they have invested in European equities and incurred withholding tax on European Union (EU) sourced dividend income? We'll discuss:

  • The principle of free movement of capital with respect to outbound dividends paid to non-EU funds.
  • Differences in treatment between Polish and U.S. funds regarding Polish dividend withholding taxes.
  • Effectiveness of fiscal supervision justification by European tax authorities addressing administrative cooperation between EU and non-EU countries.

Explore next steps U.S. and Canadian investment funds may consider regarding EU market tax claims as a result of the court decision.

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