Table of Content
1. Taxation Year-End Dates and Distribution Dates
2. Impact of Distributions
3. Distributions of funds
4. Management Fees and Redemptions
5. Estimated Distributions for 2024
6. Video – What do Pembroke Fund Distribution Mean for You?
When it comes to mutual fund distributions, there are few important facts that must be keep in mind as an investor.
- The majority of Canadian mutual funds are structured as trusts. Investors receive units of the mutual fund trust (“the Fund”) as consideration for the capital they invest, which is determined based on the net asset value per unit at the time of subscription.
- The Fund’s net earnings are allocated to investors based on their proportionate holdings in the Fund. For example, an investor that holds 10 units of a Fund with 1,000 units outstanding will receive 1% of the Fund’s distribution of earnings. The allocation of earnings by the Fund to investors are called distributions.
- The primary objective of distributions from a Fund is to pay out sufficient taxable income (including net capital gains) so that the Fund itself is not subject to income tax. Earnings retained by a Fund are generally otherwise subject to tax at the highest marginal rate.
- Distributions received by individual investors are taxed at their own marginal tax rates, which may be lower than the rate applicable to the Fund. By reducing tax paid by the Fund, investors will generally see an improvement on the return of their investment. The size of the distribution is based on the Fund’s performance.
- The timing and frequency of the distributions will vary from fund to fund.
1. Taxation Year-End Dates and Distribution Dates
| Pembroke fund | Taxation year-end of the Fund | Distribution Date |
|---|---|---|
| Pembroke American Growth Fund Inc. | December 31 | Dividend declared at the discretion of the Board of directors of the Fund |
| Pembroke Canadian Bond Fund | December 15 | Quarterly, on the final business day of March, June, September and the third Tuesday of December |
| Pembroke Corporate Bond Fund | December 15 | Quarterly, on the final business day of March, June, September and the third Tuesday of December |
| Pembroke Canadian Balanced Fund | December 15 | Quarterly, on the final business day of March, June, September and the third Tuesday of December |
| Pembroke Global Balanced Fund | December 15 | Quarterly, on the final business day of March, June, September and the third Tuesday of December |
| Pembroke Canadian Growth Fund | December 15 | Annually, on the third Tuesday of December |
| Pembroke International Growth Fund | December 15 | Annually, on the third Tuesday of December |
| Pembroke Concentrated Fund | December 15 | Annually, on the third Tuesday of December |
| Pembroke Canadian All Cap Fund | December 15 | Annually, on the third Tuesday of December |
| Pembroke Dividend Growth Fund | December 15 | Quarterly, on the final business day of March, June, September and the third Tuesday of December |
| Pembroke Canadian Growth Pooled Fund | December 15 | Annually, on the third Tuesday of December |
| Pembroke U.S. Growth Pooled Fund | December 15 | Annually, on the third Tuesday of December |
| Pembroke Global Equity Pooled Fund | December 15 | Annually, on the third Tuesday of December |
| Pembroke Global Growth Pooled Fund | December 31 | Anually on last business day of the year |
| Pembroke Genesis Pooled Fund | December 31 | Anually on last business day of the year |
Funds with a distribution on the third Tuesday of December (December 17, 2024)
What this means is that the Fund will elect a December 15 taxation year-end (Financial year-end remains December 31) and, as such, the Fund’s income and capital gains are calculated as at and including December 15.
Income and capital gains earned by the Fund during the period of December 16 to December 31 will be part of the distribution calculation for the following year (2025). The distributions will be calculated and posted on the valuation of December 17, 2024.
Electing to adopt a taxation year ending on December 15 gives fund managers more time to ensure the taxable income and distribution calculations are accurate.
2. Impact of Distributions
| Distributions from Funds held in Non-Registered Accounts | Distributions from Funds held in Registered Accounts |
|---|---|
| A. There are various categories of distributions which is ultimately dependent on the composition of earnings experienced by the Fund. Distributions from Funds held in non-registered accounts are noted on T3 slips and Relevé 16 (for Québec residents) issued to individuals resident in Canada for income tax purposes. The tax treatment for the various types of distributions incurred by these individuals are detailed in the chart below. B. Earnings where cash is not distributed to investors are considered to be reinvested in the Fund. As a result, the investor will receive additional units representing this reinvested capital and such distributions are added to the investor’s adjusted cost base (“ACB”) for tax purposes. | Distributions from Funds held in registered accounts (Registered Retirement Savings Plans, Registered Retirement Income Fund, Tax-Free Savings Accounts, Locked-in Retirement Accounts) are not taxable to investors in the year of distribution. Instead, these distributions are reinvested in the Fund and are not taxable until the investor withdrawals from their investment account. (In the case of a Tax-Free Savings Account, cash withdrawals are not taxable. In the case of a First Home Savings Accounts, eligible cash withdrawals which are used to purchase a first home are not taxable.) |
3. Types of Fund Distributions
| Distribution | What is the tax treatment? | Which fund (s) can an investor expect this type of distribution from? |
|---|---|---|
| Interest income Earned when a Fund invests in debt securities/instruments | Interest income is fully taxable at the investor’s marginal tax rates. | Pembroke Canadian Bond Fund Pembroke Corporate Bond Fund Pembroke Global Balanced Fund Pembroke Canadian Balanced Fund |
| Canadian dividend income Earned when a Fund invests in shares of Canadian public corporations | Canadian dividend income is taxable at the investor’s marginal tax rates and is eligible for a dividend tax credit. | Pembroke Canadian Growth Fund Pembroke Global Balanced Fund Pembroke Canadian Balanced Fund Pembroke Concentrated Fund Pembroke Canadian All Cap Fund Pembroke Canadian Growth Pooled Fund Pembroke Dividend Growth Fund Pembroke Genesis Pooled Fund |
| Foreign non-business income Earned when a fund invests in shares of foreign securities. This includes dividends received from foreign corporations | Gross foreign non-business income is fully taxable at the investor’s marginal tax rates. Any foreign taxes paid by the Fund on such income is allocated to investors and noted on a T3 slip and Relevé 16 (for Québec residents). A foreign tax credit is generally permitted for investors to claim. | Pembroke Corporate Bond Fund Pembroke Global Balanced Fund Pembroke International Growth Fund Pembroke Concentrated Fund Pembroke Global Equity Pooled Fund Pembroke U.S. Growth Pooled Fund Pembroke Canadian Balanced Fund Pembroke Global Growth Pooled Fund Pembroke Genesis Pooled Fund |
| Capital gains Generated from security trades incurred within the Fund resulting in gains in excess of losses. Capital losses are not allocated to investors by the Fund. | Half of capital gains are subject to tax at the investor’s marginal rates.* | Pembroke Canadian Bond Fund Pembroke Canadian Growth Fund Pembroke Corporate Bond Fund Pembroke Global Balanced Fund Pembroke Canadian Balanced Fund Pembroke International Growth Fund Pembroke Concentrated Fund Pembroke Canadian All Cap Fund Pembroked Canadian Growth Pooled Fund Pembroke Dividend Growth Fund Pembroke Global Equity Pooled Fund Pembroke U.S. Growth Pooled Fund Pembroke Global Growth Pooled Fund Pembroke Genesis Pooled Fund |
| Return of capital Generated when the fund returns to investor's their original invested capital | A return of capital is tax free to investors, and reduces an investor’s ACB in the Fund. | Pembroke funds do not normally return capital to investors. |
- A mutual fund may also be structured as a corporation. An example of a mutual fund structured as a corporation is the Pembroke American Growth Fund Inc.
- Unlike a mutual fund structured like a trust, investors are considered shareholders and such funds do not distribute its earnings to shareholders. Instead, Directors of the mutual fund corporation may occasionally declare dividends to investors.
- Canadian dividend income is taxable at the investor’s marginal tax rates and is eligible for a dividend tax credit. Such dividends are reported to investors on a T5 slip and Relevé 3 (for Québec residents).
* Earlier in the year, the federal government proposed to increase the capital gains inclusion rate for gains/losses realized after June 24, 2024 from 50% to 67%. For individuals and certain trusts, the 50% inclusion rate would continue to apply for the first $250,000 of net capital gains (i.e. capital gains less capital losses) in a given year.
For the 2024 year, the full $250,000 threshold is available on net capital gains triggered between June 25 and December 31, 2024. Any unused portion of the $250,000 threshold does not get carried forward to next year.For all other taxpayers, including corporate taxpayers, the $250,000 annual threshold is not available; thus the 67% capital gain inclusion rate is applicable on every dollar of net capital gains beginning June 25, 2024.
While this legislation has not yet passed into law, taxpayers should be aware of the potential change to the capital gains inclusion rate. For Pembroke investors, the capital gain inclusion rate changes would be applicable to both capital gain distributions by the Funds and any net capital gains triggered on dispositions of Fund units.
4. Management Fees and Redemptions
Management fees are charged outside of all Pembroke Funds, meaning a portion of investors’ units in the Fund are redeemed on a monthly basis to satisfy the payment of management fees. As a result, an investor will likely experience a capital gain on these redemptions. Similarly, investors that request cash redemptions from their investment holdings will also trigger a capital gain. The size of the capital gain is dependent on the amount redeemed and the individual’s ACB in the Fund. Half of capital gains are subject to tax at the investor’s marginal rates.
A summary of such dispositions resulting from management fees and cash redemptions will be reported to investors on a T5008 and Relevé 18 (for Québec residents) at year-end.
Furthermore, a letter summarizing management fees paid will be distributed to investors. It is recommended that you speak with your personal accountants regarding the deductibility of management fees for income tax purposes. Management fees incurred on Funds held in registered accounts are not deductible for income tax purposes.
5. Estimated Distributions for 2024
Below are the 2024 year-end estimated distributions for the Pembroke Mutual Funds and Pooled Funds. Please keep in mind that these amounts are only estimates and could change.
| Mutual Funds | Capital Gain/Unit | Income/Unit |
|---|---|---|
| Pembroke Canadian Bond Fund | $0 | Regular Quarterly Income |
| Pembroke Corporate Bond Fund | $0.18363 | Regular Quarterly Income |
| Pembroke Canadian Balanced Fund | $1.30015 | Regular Quarterly Income |
| Pembroke Global Balanced Fund | $0.03513 | Regular Quarterly Income |
| Pembroke Canadian Growth Fund | $5.06673 | $1.31495 |
| Pembroke International Growth Fund | $0 | $0.34790 |
| Pembroke American Growth Fund Inc. | $0 | $0 |
| Pembroke American Growth Fund Inc. $US | $0 | $0 |
| Pembroke Concentrated Fund Class A | $0 | $0.01780 |
| Pembroke Concentrated Fund Class A $US | $0 | $0.01277 |
| Pembroke Concentrated Fund Class F | $0 | $0 |
| Pembroke Concentrated Fund Class F $US | $0 | $0 |
| Pembroke Concentrated Fund Class I | $0 | $0.00262 |
| Pembroke Canadian All Cap Fund | $0.02939 | $0.15070 |
| Pembroke Dividend Growth Pooled Fund | $1.11394 | Regular Quarterly Income |
| Pooled Funds | Capital Gain/Unit | Income/Unit |
|---|---|---|
| Pembroke Canadian Growth Pooled Fund | $0.38975 | $0.38451 |
| Pembroke US Growth Pooled Fund | $0.43046 | $0.12215 |
| Pembroke US Growth Pooled Fund $US | $0.30881 | $0.08763 |
| Pembroke Global Equity Pooled Fund | $0.10782 | $0.17903 |
| Pembroke Global Growth Pooled Fund | $0 | $0.01027 |
| Pembroke Genesis Pooled Fund Founder’s Class | $1.05499 | $0 |
| Pembroke Genesis Pooled Fund Class A Series 1 | $0.36165 | $0 |
| Pembroke Genesis Pooled Fund Class A Series 9 | $0.86235 | $0 |
| Pembroke Genesis Pooled Fund Class A Series 12 | $0.81909 | $0 |
| Pembroke Genesis Pooled Fund Class A Series 14 | $0.84808 | $0 |
| Pembroke Genesis Pooled Fund Class A Series 17 | $0 | $0 |
(*) The Pembroke Pooled Funds are prospectus-exempt products that are offered to investors who meet the definition of an “accredited investor” under securities legislation.
Please contact your Pembroke Representative for further details.
6. Video – What do Pembroke Fund Distributions Mean for You?
On November 10, 2022, we held a webinar discussing mutual fund distributions, and how they can be part of your tax plan.
