Draft FATCA Regulations. Submission from the Association of Investment Companies

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1 Draft FATCA Regulations Submission from the Association of Investment Companies Overview The Association of Investment Companies (AIC) welcomes the opportunity to comment on the draft FATCA regulations. In summary, closed-ended publicly traded investment companies do not give rise to a significant risk of tax evasion by US citizens. We therefore recommend that consideration be given to minimising the impact of FATCA on these entities. Background The AIC s members are closed-ended corporate investment vehicles whose shares are traded on UK public stock markets. Our members include investment trust companies and venture capital trust (VCT) companies. A UK investment trust company is a collective investment fund constituted as a public limited company and listed on the London Stock Exchange. Subject to meeting a number of conditions, an investment trust company benefits from favourable UK tax treatment (although they are subject to corporation tax on their income). VCT companies are another form of tax-favoured UK collective investment vehicle designed to encourage UK tax paying individuals to invest indirectly in a range of small higher-risk trading companies whose shares and securities are not listed on a recognised stock exchange. The shares in a VCT company must themselves be listed on the London Stock Exchange. Again, the tax treatment is dependent upon a number of conditions being met by the VCT company. The universe of investment companies represented by the AIC is diverse. The largest have assets of one or two billion pounds. The smallest have assets valued at just a few tens of millions. They hold asset classes including public and private equity and venture capital. These companies are not an attractive option for those seeking to avoid their tax obligations because their holdings are exposed to significant risk and do not allow control over the investment approach. An investor in a closed-ended investment company, unlike an openended investment company or unit trust, does not have the right to require redemption of his shares; the only expectation of realising his investment is through a sale on the stock market, often at a considerable discount to the underling net asset value of the shares (see Annex). The shares would be traded by brokers and other intermediaries, who would be expected to be participating FFIs. Closed-ended investment companies are also highly transparent and regulated. As a UK-orientated sector, our members are unfamiliar to US investors. They therefore present a low risk of tax evasion and we hope the IRS will look sympathetically on our representation (see Annex for further discussion of this issue). Benefits of reducing extraneous reporting by investment companies The IRS faces a significant challenge in preparing for and administering the FATCA requirements. In recognition of this it has scope to reduce extraneous reporting by FFIs. Clearly, concessions over reporting can only be granted when this does not compromise the ability of the IRS to capture information on potential tax evaders. This should not be an 1

2 issue where UK investment companies are concerned because, as discussed, they present a low risk of tax evasion (see Annex). However, the AIC believes that delivering proportionate compliance obligations for these FFIs will deliver other benefits for the IRS: Minimise the IRS s administrative burden and systems costs: reducing the number and type of participating FFIs will significantly simplify the IRS s infrastructure needs. Reduce provision of extraneous information: which will otherwise increase the pressure on IRS systems, require greater staff and financial resources, and, most importantly, make it more difficult for the IRS to identify key information on potential US tax evaders. Maximise global demand for US assets: including Treasury Bonds and company shares. Support the market for US service providers: including banking, custodial and fund management services, which generate significant corporate tax revenues. The AIC s recommendations, set out below, will help deliver all these outcomes. This will be achieved by considering a broader application of the concept of deemed compliance and reducing the threshold for FFIs to be considered regularly traded on an established securities market. Existing categories of deemed compliant entities Investment companies offer access to expert fund management and a diversified portfolio of assets. Unlike open-ended investment funds, our members are closed-ended so that an investor subscribes for shares on launch or subsequently acquires shares on a stock market. Similarly, an investor s interest in the company is not redeemed through the fund manager, it is secured by selling their shares on a stock market. Also, these companies are governed by a board of directors with legal (company law) obligations to uphold shareholders interests. A new category of deemed compliant FFI was introduced in the draft regulations, namely restricted funds, which should reduce the impact of FATCA on open-ended funds. Closedended investment companies do not pose any greater risk of tax evasion than open-ended funds. Unfortunately, they will not be able to meet the conditions set out in the draft regulations for deemed compliance. Closed-ended investment companies will not be able to avail themselves of restricted fund status as they will be unable to comply with the restrictions imposed on the distributors of the fund. The investment company has no control over which brokers sell its shares or to whom they sell shares. Further, closed-ended investment companies will not be able to avail themselves of the local FFI category of registered deemed compliant status as this is not available to investment companies, notwithstanding that some or all of the remaining requirements of this category could be met. 2

3 However, investment companies do exhibit many of the characteristics of FFIs which otherwise may be able to take advantage of this status. This should be recognised in the implementation of FATCA, as explained below. Deemed compliance for defined categories of investment companies Our primary recommendation is that investment companies that have the following characteristics should constitute a further category of registered deemed compliant entities under the FATCA regulations. They should also be treated as deemed compliant under the proposed intergovernmental agreement with the UK: Closed-ended (i.e. which do not offer redemption on demand); Corporate (i.e. constituted as a company with a board of directors with fiduciary duties to shareholders); Whose shares are traded on public markets. The scope of public markets should at least include EU regulated exchanges, which are governed by the Transparency Directive, Prospectus Directive and Consolidated Admissions and Reporting Directive (CARD). These rules create high standards and are designed to ensure transparent and orderly markets for regularly traded shares; and Where the shares are required to be widely held, either as a result of non-close company test and/or through the liquidity requirements under the rules of the relevant established securities market (see Annex for further discussion). Investment trust companies and VCTs should be able to meet these requirements. However, if required, it might be possible to refine the excluded category further so that, if shares are acquired by US persons or a non-participating FFI, the company would exercise powers to compulsorily transfer those shares. Many investment trust companies already have the powers to compulsorily transfer any shares acquired by US investors (see Annex). Shares regularly traded on an established securities market If deemed compliant status for specified investment companies is not granted, or when investment companies cannot meet the requirements, for example because they are not fully listed, they may fall within the provisions for FFIs whose shares trade on an established securities market. Despite our members being traded on established securities markets (such as the main market of the London Stock Exchange), some of our members will be unable to meet the requirement of regularly traded as currently defined in the draft Regulations. The 10% turnover requirement and minimum trading days requirement are unnecessary and restrictive, as these companies will already have conditions imposed on them in relation to liquidity by the London Stock Exchange rules (see Annex). It threatens to bring into full compliance a number of investment companies who would not otherwise have full reporting obligations. The AIC s primary recommendation is that, where the traded shares are widely held, either as a result of the non-close company requirements and/or liquidity requirements under the rules of the relevant established securities market (see Annex) it is not necessary to meet the turnover threshold or the minimum trading day requirement. 3

4 In the alternative, if this does not meet the requirements of the IRS, the AIC recommends that, for investment companies seeking to take advantage of the regularly traded provisions, the 6% requirement in the limitations of benefits article in the UK-US double tax agreement be adopted rather than 10%. This reflects the prevailing US expectation and recognises the high standards which otherwise apply in the UK. If a turnover threshold is required, the AIC recommends that turnover be calculated by reference to the financial year of the investment company. The AIC also recommends that the investment company would be required to self-assess its turnover within four months after the end of its financial year. An investment company which is listed on the London Stock Exchange would be required under the Listing Rules to make public its annual financial report at the latest four months after the end of each financial year. It should be noted that, whilst a share trade may actually take place on, say, the London Stock Exchange, it may be reported elsewhere, say, on Plus. The AIC therefore recommends that the calculation of any turnover threshold should allow inclusion of all trades reported on an established securities market regardless of whether the securities are actually listed on that market or traded on that market. Otherwise this may lead to significant under-reporting of turnover. If a turnover threshold is required, the AIC recommends that failure to exceed this test in any one year does not trigger compliance with the full requirements of a participating FFI. Such a consequence for failing to meet the turnover test by a marginal amount for one year would be disproportionate given the costs involved in setting up the systems required to report the necessary information to become a participating FFI. The consequences would be particularly severe if the turnover test were met the following year and no further reporting were required. Accordingly, the AIC recommends that any turnover threshold be looked at on a 3 year look back basis so that shares would be treated as regularly traded if the turnover requirement was met during any one of the three previous financial years. Alternatively, the AIC recommends that the investment company would need to fail the turnover test for two consecutive financial years before being required to report on its shareholders. If this is not acceptable, the cliff edge threat of using a one year basis could be avoided by using a rolling average basis over a number of years. Any alternative option would give the investment company warning of the impending requirements under the FATCA regime. The AIC recommends that, having failed the turnover test, the investment company would have a further six months from the requirement to report its turnover in which to become a participating FFI or face withholding. For newly launched investment companies which are traded on an established securities market, the AIC recommends that the investment company is deemed to meet the turnover test for the first two years from launch, at which point it would then need to assess whether the test described above has been met. This would give a newly launched listed investment company time to meet the turnover threshold. Even if our members do meet the regularly traded requirement then there remains considerable uncertainty on the operation of the passthru payment regime. It is not clear whether an investment company whose shares are regularly traded on established securities market (and therefore has no financial accounts in respect of its shares and would therefore 4

5 not be expected to do any due diligence in determining whether its shareholders are US persons), would then be obliged to withhold on passthru payments to its shareholders who are non-participating FFIs. It would seem contradictory if it were obliged to then assess which of its shareholders were non-participating FFIs whilst ignoring any direct US shareholders on the register. Given the prolonged uncertainty regarding this aspect of the regime, it is difficult, if not impossible, for some of our members to assess the impact of the FATCA regime and plan accordingly. The AIC recommends that it would not be appropriate to impose the passthru payment regime in respect of shares which are regularly traded on an established securities market but held by a non-participating FFI. Payment of Dividends Dividends are frequently paid by our members using a transfer agent. The AIC recommends that the transfer agent should not have any more extensive obligations under the FATCA regulations than the entity on whose behalf it is acting as transfer agent. For more information on the issues raised in this note contact: Janette Sawden, Taxation Adviser, The Association of Investment Companies April

6 Annex Low risk of using investment companies to evade tax Investment companies do not give rise to a significant risk of tax evasion by US citizens. Investment companies are inherently unattractive vehicles to use for the purposes of tax evasion because of the characteristics of the structure. Widely held ownership: To achieve tax favoured investment trust company status, the investment trust company must not at any time be a close company during its accounting period, in other words it must be widely held. 1 Further, in order to comply with the Listing Rules (LR ) 25% or more of the shares must be held by the public in one or more European Union member states. If this requirement is no longer met, the Financial Services Authority may cancel the listing of the shares on the London Stock Exchange. No right of redemption or return of capital: Investment companies are closed-ended companies which means that, unlike their open-ended counterparts, investors have no right to require redemption of their shares by the investment company. The only way that an investor can expect to realise their investment is by sale of their shares in the market, which will be carried out by brokers. We would expect brokers to be participating FFIs. The only cash flows going from the investment company to investors are the payment of dividends. Investment risk: Investors capital is exposed to investment risk. Changes in the value of the underlying portfolio will be reflected in increases and falls in the company s share price. Income from an investment company share is payable in the form of a dividend. Again, the amount paid out varies according to the performance of the underlying portfolio. Discount risk: The investment return for investment company shareholders varies from the net asset value (NAV) of the portfolio. This is because the level of the share price is influenced by the balance of supply and demand for the company s shares (in addition to, for example, the investment performance). Investment companies tend to trade at a discount to the NAV. The average discount across the sector is currently 8%. Investment companies investing in certain asset classes have far wider discounts. For example, specialist financial investment companies currently have a discount of just under 35%. Even investment companies with a global growth investment exposure have a discount of 10.5%. While discount risk is just one of the factors taken into consideration by genuine long-term investors, it is unlikely to be attractive for an individual simply seeking to shield assets from tax. Lack of control: Investment companies are governed by a board of directors, who oversee the investment of the portfolio and other key issues related to the operation of the company. They run the company in the interests of all the shareholders and within 1 Broadly speaking, a close company is defined in the UK tax legislation as being one which is under the control of five or fewer shareholders or where more than half the assets of the company would be distributed to five or fewer shareholders in the event of the winding up of the company. 6

7 boundaries (critically including the investment policy which sets the investment style and asset allocation). There is not even any guarantee that an investment company will offer an on-going shelter. A number of investment companies have periodic continuation votes and any company could be wound-up if shareholders were to vote for that outcome. While shareholder democracy is an attractive feature for ordinary investors, it is not something likely to appeal to an individual seeking to evade their tax obligations as they have no long-term guarantees about how the company will operate. Regulation: Investment companies are subject to a high level of regulation. This includes: reporting and transparency obligations, prospectus rules, and requirements to report against recognised accounting standards, such as UK GAAP or IFRS. They will also be within scope of the EU s Alternative Investment Fund Manager s (AIFM) Directive (expected to take effect in 2013). These obligations are appropriate to protect investors but create costs and obligations which are unlikely to be attractive for individuals seeking to evade tax. Transparency of major holdings: The vast majority of the sector trades on the London Stock Exchange and other European regulated markets. These are subject to major shareholding rules which require disclosure of those with major holdings. In the UK disclosure is required for holdings of 3% (with further disclosures required for each 1% additional holding). Rules governing all European regulated markets require disclosure once a 5% holding is achieved (and for each 5% acquired thereafter). Lack of familiarity/marketing to US investors: The investment company sector represented by the AIC is overwhelmingly purchased by UK investors. Investment companies also tend to avoid marketing in the US because having US shareholders on the register creates other regulatory obligations separate from those implied by FATCA (for example, under Investment Companies Act, 1940, and the Passive Foreign Investment Companies reporting requirements). These companies therefore tend not to be marketed in the US and we anticipate that US holdings are negligible. Indeed, in relation to VCT companies, the principal tax relief is only available to UK taxpayers who subscribe for the shares in the VCTs and is not available if the VCT shares are purchased on the secondary market. As a result there is a very illiquid market in the VCT company shares. As a consequence of these factors, the UK investment company sector is not a familiar investment opportunity for US investors, which decreases further the likelihood that they would be used for the purposes of tax evasion. The corporate structure, governance arrangements, exposure to investment and other risks, as well as their regulatory and transparency obligations make investment companies equivalent in critical aspects to quoted trading companies. These have already been identified as unlikely to be utilised for tax evasion purposes and excluded from the scope of FATCA. The same is true for investment companies. 7

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