The Portfolio Management Association of Canada (PMAC), through its Industry, Regulation & Tax Committee, is pleased to have the opportunity to provide comments on Department of Finance Canada (Finance) – Consulting Canadians on Draft Tax Legislative Proposals (the Consultation).
As background, PMAC represents over 250 investment management firms that collectively manage over $1.8 trillion in assets under management, all of whom are registered as portfolio managers with one or more of the Canadian Securities Administrators (CSA). PMAC members manage investment portfolios for private individuals, institutions, foundations, universities and pension plans.
Our submission herein is focused on the proposed beneficial ownership reporting requirements for certain trusts set out in the Consultation. We believe that this particular proposal would adversely impact the ease of doing business in Canada to the detriment of the many Canadian savers that are invested in unit trusts (commonly called “pooled funds” in the industry), all as more fully set out below.