Home Viewpoints
TOPICS
401(k)
Commodity Investments
Events
Exchange-Traded Funds
Financial Markets
Fund Governance
Fund Regulation
GMM
Government Affairs
ICI Global
International
Investment Education
Investor Research
Money Market Funds
Operations and Technology
Policy Research
Retirement Policy
Retirement Research
Savings
Taxes
ARCHIVE
FTT Would Shut Financial Institutions in Participating Countries Out of Repo Market
By Shelly Antoniewicz and Peter Brady
April 22, 2013
The European Commission has proposed imposing a 0.1 percent (10 basis points) levy on financial transactions. As ICI has detailed, this financial transaction tax (FTT) would have a host of negative consequences, including harm to investors and extraterritoriality.
Here’s another strike against the proposal: its impact on the market for repurchase agreements (repo).
Proponents claim that the proposed tax—0.1 percent of the value of repo transactions involving financial institutions from the 11 countries that have signed on in support of the proposed tax—would hardly affect market participants. But the opposite is true. For example, the FTT would be felt acutely by investors (including U.S. money market funds) conducting repo transactions in which financial institutions from those 11 countries were counterparties. Thus, the tax likely would work to eliminate repo as a source of funding to affected financial institutions, particularly French and German banks.
Background on Repurchase Agreements
Repos are a form of short-term funding used largely by financial institutions such as banks. The financial institution sells the securities to investors, such as a money market fund, usually on an overnight basis, and agrees to buy them back at a higher price reflecting the cost of funding.
European FTT Would Weigh Heavily on Repo Yields
The FTT would create a substantial drag on repo yields for investors conducting repo transactions with affected financial institutions. In fact, it would produce negative net yields on repo—both in the current low interest rate environment and at more normal interest rate levels for shorter duration repo.
The proper measure of the burden of the tax is not the tax rate on assets involved in a single repo transaction, but the effect the tax has on the net yield of covered repo holdings. Depending on the maturity, the cumulative annual tax on covered repo holdings would be 5 percent to 25 percent. In other words, annual repo yields would need to rise above at least 5 percent for investors to receive a positive net yield on repo “covered” or captured by the FTT. Even for covered repos with longer maturities, investors would be hard-pressed to justify an investment and would look elsewhere to find higher after-tax returns.
Cumulative Effect of FTT on Repo
The burden that transaction taxes place on investors would depend on the amount and maturity of covered repos held in their portfolios. The shorter the maturity of the covered repo, the higher the cumulative annual tax rate would be, because the tax would be paid each time the investor renewed (rolled over) the repo. Figure 1 illustrates the multiplicative effect of this “small” 10 basis point tax.
For example, at year-end 2012, U.S. money market funds held $139 billion in covered repo, all with financial institutions in Germany and France. Repos tend to have short maturities, and 95 percent of covered repo held by U.S. money market funds had a remaining maturity of seven days or less. If the $139 billion in covered repo had a seven-day maturity and covered repo holdings were not reduced in response to the tax, this dollar amount would be rolled over 52 times in a year and would cost a little more than $7 billion in taxes. In this case, the cumulative annual tax would represent 518 basis points (5.2 percent) of covered holding, not 10 basis points (0.1 percent). As the maturity of the covered repo shortens up, the cumulative annual tax rises dramatically. If all covered repo were overnight, the U.S. money market fund industry would pay nearly $35 billion in taxes annually, or 2,503 basis points (25 percent) of their covered holdings.
Figure 1
Tax Rises Quickly as Maturity of Repo Declines
| Covered repo1 Billions |
Maturity Days |
Implied annual turnover | Tax rate Basis points |
Cumulative annual tax3 Billions |
Cumulative annual tax rate4 Basis points |
| $139 | 7 | 52 | 10 | $7.2 | 518 |
| 139 | 5 | 73 | 10 | 10.1 | 726 |
| 136 | 3 | 122 | 10 | 16.9 | 1,215 |
| 139 | 1 | 2502 | 10 | 34.8 | 2,503 |
1Source: ICI tabulations of Form N-MFP data as of December 31, 2012.
2Accounts for weekends and holidays.
3Calculated as covered repo multiplied by implied annual turnover multiplied by (tax rate/10,000).
4Calculated as (cumulative annual tax/covered repo) multiplied by 10,000.
Likely Outcome of FTT: Investors Shift and a Loss of a Funding Source
The proposed tax on repo holdings would represent a substantial burden in any interest rate environment, but certainly would eliminate repo between investors in the short-term markets and financial institutions in the 11 participating countries given current yields. At the end of March, a seven-day repo collateralized with U.S. Treasury securities yielded just 0.2 basis points, substantially below the 10 basis point proposed tax for this transaction (Figure 2). To compensate for the tax, financial institutions in the 11 countries, including French and German banks, would need to pay about 50 times as much for seven-day repo funding at current yields.
Figure 2
Yields* on Seven-Day Repo Too Low to Support European Commission FTT
Basis points, month-end, January 2000–March 2013

*Represents yield received for one repo transaction over a seven-day period; not expressed at an annual rate.
Source: Bloomberg
A more likely outcome is that investors, including U.S. money market funds, would shift to assets with equivalent risk but higher after-tax returns. Banks in the 11 countries with the FTT would lose repo as source of funding; the effect of the “small” FTT would be enormous.
Learn more about FTTs at our resource center.
Shelly Antoniewicz and Peter Brady are senior economists at ICI.
TOPICS: TaxesICI GlobalMoney Market Funds
The Extraordinarily Extraterritorial Proposal to Tax Global Financial Transactions
By Keith Lawson
April 10, 2013
The financial transaction tax (FTT) being considered by several European countries would have an extraordinary extraterritorial effect.
TOPICS: TaxesICI Global
Individual Investors Will Be Harmed by Financial Transaction Taxes
By Keith Lawson
March 27, 2013
A fundamental tenet of the argument for a financial transaction taxes (FTTs) is that individuals would not be harmed.
TOPICS: TaxesICI Global
ICI Global Welcomes Improvements in Final FATCA Regulations
By Ianthe Zabel
January 18, 2013
TOPICS: TaxesInternational
In Case You Missed It: “Don't Enact Financial Transaction Taxes”
By Ianthé Zabel
December 21, 2012
The Hill has just posted a commentary from ICI President and CEO Paul Schott Stevens in which he discusses financial transaction taxes (FTTs) and why U.S. policymakers would be well-advised to avoid enacting them.
TOPICS: TaxesFinancial MarketsGovernment Affairs
Fund Industry Leaders Urge “Sustainable Course” for U.S. Finances
By Mike McNamee
December 18, 2012
For the good of investors and all Americans, leaders across the fund industry have been outspoken about the necessity of the U.S. government taking a sound and sustainable approach to its finances.
TOPICS: TaxesFinancial Markets
ICI Supports Legislation to Shield U.S. Investors from Foreign Financial Taxes
By Ianthé Zabel
November 30, 2012
ICI issued the following statement in support of H.R. 6616, a bill introduced by Representative Tom Price (R-GA) and designed to protect American investors from the application of extraterritorial financial transaction taxes.
TOPICS: TaxesFinancial MarketsGovernment Affairs
FATCA Must Not Undercut the Advantages That U.S. ETFs Offer Global Investors
By Keith Lawson and Ryan Lovin
November 6, 2012
In recent months, ICI has continued to engage closely with regulators to share our concerns and suggestions for implementing the Foreign Account Tax Compliance Act (FATCA).
TOPICS: TaxesICI Global
More Time Is Needed to Ensure Effective FATCA Implementation
By Keith Lawson
November 6, 2012
On January 1, 2013, various rules implementing the Foreign Account Tax Compliance Act (FATCA) begin to take effect.
TOPICS: TaxesICI Global
Transparency and Inclusiveness Are Key to Addressing FATCA Challenges
By Keith Lawson
October 3, 2012
U.S. officials, their counterparts overseas, and representatives from the private sector continue to make impressive headway in implementing the Foreign Account Tax Compliance Act (FATCA).
TOPICS: TaxesICI Global
Regulators and Industry Exchange FATCA Insights at ICI and ICI Global Webinar
By Keith Lawson
August 30, 2012
Senior officials from the U.S. Treasury Department and the Organization for Economic Cooperation and Development (OECD), along with industry experts, recently engaged in a very informative webinar discussion regarding a model intergovernmental agreement (IGA) for implementing the Foreign Account Tax Compliance Act (FATCA). The model IGA, as discussed in an earlier ICI Viewpoints post, was developed by the Treasury Department with the active cooperation of senior tax officials from France, Germany, Italy, Spain, and the United Kingdom.
TOPICS: TaxesICI Global
How the Model Intergovernmental Agreement Reduces FATCA Burdens
By Keith Lawson
August 1, 2012
The U.S. Treasury Department has made significant progress with its July 26 release of a model intergovernmental agreement (IGA) for implementing the Foreign Account Tax Compliance Act (FATCA). This model IGA—developed with the active cooperation of senior tax officials from France, Germany, Italy, Spain, and the United Kingdom—addresses many of the U.S. and global fund industries’ concerns with the substantial compliance burdens placed by FATCA on funds, their distributors, and their investors. ICI and ICI Global applaud this development and look forward to continuing our dialogue with these governments on the FATCA regulations and the IGAs they craft based on the model.
TOPICS: TaxesICI Global
FATCA’s Challenges for Global Investment Funds
By Keith Lawson
May 30, 2012
The rules proposed to implement the Foreign Account Tax Compliance Act (FATCA) pose a number of serious challenges for ICI Global members. ICI Global’s recent comment letter to the U.S. Department of the Treasury and the Internal Revenue Service (IRS) made several recommendations on how the FATCA rules should be amended so that ICI Global’s members—regulated funds that are publicly offered to investors in leading jurisdictions worldwide—can overcome these challenges without compromising the tax compliance benefits contemplated by FATCA.
TOPICS: TaxesICI Global
Improving FATCA: Three Key Areas
By Keith Lawson
May 30, 2012
Congress enacted the Foreign Account Tax Compliance Act (FATCA) in 2010 in response to efforts by certain U.S. taxpayers to hide assets and income subject to U.S. tax. To enhance tax compliance by U.S. taxpayers, FATCA imposes significant new customer identification, reporting, and withholding obligations on both U.S. and foreign financial institutions. Any foreign financial institution that fails to attain FATCA compliance will suffer 30 percent withholding tax on all payments from U.S. sources, including income receipts and sales proceeds.
TOPICS: Taxes
Achieving the Proper Balance on FATCA
By Keith Lawson
February 8, 2012
ICI and ICI Global have engaged actively with Treasury and the Internal Revenue Service (IRS) as they have crafted the proposed Foreign Account Tax Compliance Act (FATCA) regulations, which were issued today. Our message has been simple: ensure that the tax compliance benefits anticipated by FATCA, which we support strongly, justify the costs that will be imposed.
TOPICS: Taxes
Fund Investment in Commodities Provides Opportunity and Diversification for Investors
By Karen Lau Gibian and Rachel H. Graham
January 26, 2012
On Capitol Hill, a hearing at the Permanent Subcommittee on Investigations (PSI) raises questions about mutual fund investors’ ability to get commodity exposure in their portfolios and suggests the Internal Revenue Service (IRS) should no longer allow this type of investment.
TOPICS: TaxesFinancial MarketsFund RegulationCommodity Investments
Now Is the Time to Put America on a Path of Fiscal Responsibility
By Paul Schott Stevens
November 21, 2011
On behalf of funds and the 90 million investors that they serve, fund industry leaders are sending a simple but urgent message to Congress and the White House: the time has arrived to put America’s fiscal house in order.
Thirty executives of companies represented on ICI’s Board of Governors, the chair of the Independent Directors Council, and I are joining together to send a letter to the co-chairs of the Joint Select Committee on Deficit Reduction—known as the “Super Committee”—every other member of Congress, and the President.
TOPICS: TaxesFinancial Markets
Changes to Cost Basis Rules Provide Investors More Flexibility
By Karen Lau Gibian
August 26, 2011
In a positive development for fund shareholders, the Department of the Treasury and the Internal Revenue Service have issued new cost basis reporting rules that enhance a fund’s ability to provide shareholders with average cost basis information. Fund shareholders have become quite familiar with average cost basis information, which many funds have been providing to their shareholders voluntarily for 20 years or more. The regulatory change makes it more likely that funds will continue to use this method as their default method for redeemed shares.
TOPICS: Taxes
Cracking Down on Tax Evaders Without Cracking Up U.S. Capital Markets
By Keith Lawson
June 15, 2011
The Foreign Account Tax Compliance Act (FATCA) is a law designed to ensure that U.S. persons holding assets through accounts in foreign financial institutions comply with their U.S. tax obligations. In other words, the law aims to crack down on tax evasion through offshore investments. It is set to apply to payments made beginning January 1, 2013.
TOPICS: TaxesInternational
ICI Urges Change in Cost Basis Rules to Avoid Harm to Fund Investors
By Karen Lau Gibian
January 13, 2011
A provision in the new cost basis rules could hurt fund investors. We recently contacted the Internal Revenue Service (IRS) and the U.S. Department of the Treasury, urging them to amend the rules to avoid this outcome.
TOPICS: Taxes
New Law Will Make Funds More Efficient and Reduce Need for Amended Tax Returns
By Ianthe Zabel
December 23, 2010
ICI President and CEO Paul Schott Stevens made the following statement upon the enactment of H.R. 4337, a bill that updates and simplifies a number of mutual fund tax rules...
TOPICS: TaxesGovernment Affairs
ICI Supports House Vote on Bill to Update Mutual Fund Tax Laws
By Ianthe Zabel
December 17, 2010
ICI President and CEO Paul Schott Stevens made the following statement about recent U.S. House of Representatives approval of H.R. 4337, as amended and approved by the U.S. Senate.
TOPICS: TaxesGovernment Affairs
Enactment of Tax Bill Extending Current Tax Rates on Investments Comes at Critical Time and Brings Certainty
By Ianthe Zabel
December 17, 2010
ICI President and CEO Paul Schott Stevens today issued the following statement on enactment of a tax bill that will maintain and extend the current tax rates on capital gains and dividends for two years...
TOPICS: TaxesGovernment Affairs
ICI Applauds Senate Approval of Bill to Modernize Mutual Fund Tax Laws
By Ianthe Zabel
December 9, 2010
ICI President and CEO Paul Schott Stevens made the following statement about recent U.S. Senate approval of H.R. 4337.
TOPICS: TaxesGovernment Affairs
Fund Investors, Economy Will Benefit From Certainty and Lower Tax Rates on Investments
By Ianthe Zabel
December 9, 2010
ICI President and CEO Paul Schott Stevens today issued the following statement on the tax legislation, H.R. 4853 as amended, approved by the U.S. Senate in a strong bipartisan vote.
TOPICS: TaxesGovernment Affairs
Copyright © 2013 by the Investment Company Institute
