U.S. Legal Considerations for Canadian Banks

04/28/2015 10:00 a.m. - 03:00 p.m.

Banking + Financial Services, Corporate Finance | Capital Markets, Financial Institutions + Financial Services, and Investment Management

The Fairmont Royal York
100 Front Street West
Toronto, ON M5J 1E3

Oliver I. IrelandJames Schwartz, and Julian E. Hammar

James SchwartzJulian E. Hammar, and Oliver I. Ireland


Harrison Lawrence
(212) 336-4004

Please join Morrison & Foerster and McCarthy Tétrault as we present three complimentary sessions addressing key issues for Canadian firms doing business in the United States.


Tax Update: U.S. Capital Markets – Download Presentation Materials 
10:00 a.m. – 11:00 a.m.

This session will discuss current issues in the U.S. federal income tax treatment of financial instruments and financial institutions, including:

  • Cross-border “dividend equivalents” on derivatives:  Section 871(m) and IRS guidance;
  • Conversion adjustments on convertible bonds treated as dividends for U.S. tax purposes;
  • U.S. tax treatment of “negative” interest;
  • Financial transactions tax proposal; and
  • U.S. tax reform including VAT.


  • Thomas Humphreys
  • Remmelt Reigersman

Roundtable Discussion of Volcker Rule Compliance Considerations for non-U.S. Banks – Download Presentation Materials
11:00 a.m. – 12:30 p.m.

Canadian banks have extensive U.S. operations.  In this session, we will discuss some of the key developments that have changed and will change foreign bank practices. Topics include:

  • SOTUS for Proprietary trading & Funds;
  • Banking Entity v. Fund;
  • Liquidity Management;
  • Customer transactions and funds;
  • Insurance;
  • Pension Funds; and
  • Conformance period.


  • Julian Hammar
  • Oliver Ireland
  • James Schwartz

12:30 p.m. – 1:00 p.m.

Resolution Schemes for U.S. and Canadian Banks – Download Presentation Materials
1:00 p.m. – 2:30 p.m.

This session will cover the main aspects of the proposed US and Canadian bank resolution schemes (the “single point of entry” regime in the US and the “bail-in” regime in Canada), in light of the Financial Stability Board’s Key Attributes of Effective Resolution Regimes for Financial Institutions.


  • Ana Badour, McCarthy Tétrault
  • Oliver Ireland

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