Michael Noonan (Limerick City, Fine Gael) | Oireachtas source

It simply needed to be clarified; it was not a big issue. The note I have says the Ireland-US tax treaty makes express reference to Irish regulated funds in the definition of who is a resident of Ireland in Article 4 of the treaty. The treaty provides that collective investment undertakings in Ireland are treated as residents of Ireland for treaty purposes. The funds industry has raised a concern that if the definition is not updated to include an Irish collective asset-management vehicle, ICAV, there may be some uncertainty as to the application of the Ireland-US tax treaty. As one of the main advantages in introducing the ICAV was that it would be more user friendly for the purposes of the check-the-box provisions of the US tax code, it has been deemed necessary to update the definition of "collective investment undertaking" to include ICAVs. This should enhance the attractiveness of the ICAV to investment managers seeking to market and invest their funds in the US.