Decision

To APPROVE expenditure of $25-35k (approximately £20-28k) to update a US tax opinion.

Reasons for the decision

The Pension Fund makes investments in the United States (US), some of which attract a particular tax treatment which, subject to demonstrating certain characteristics, GMPF can gain exemption from.

To support the obtaining of such an exemption, the Fund procured written opinion from a US based law firm in 2020 as to its entitlement.  Since this time, there have been changes to the relevant tax law such that it is prudent to have the opinion updated, so that the Fund can either (a) continue to receive the related tax exemption, or (b) adapt in the most appropriate way if the changes to US tax law have made the exemption unavailable to GMPF.