Adrienne Baker

Adrienne Baker

Dechert LLP

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Latest Publications


The Common Reporting Standards - New Global Tax Information Exchange Regime Begins January 2016

The Common Reporting Standard (“CRS”) will impose new investor due diligence and reporting obligations on funds and other financial institutions based in “early adopter” participating jurisdictions, with effect from January...more

11/11/2015 - Common Reporting Standard (CRS) Cross-Border Transactions Due Diligence FATCA Financial Institutions Information Sharing International Tax Issues Investment Funds OECD UK

A Sea Change for Waive-rs? - Proposed Regulations Address Tax Treatment of Management Fee Waivers

The U.S. Treasury Department (“Treasury”) and the Internal Revenue Service (the “IRS”) have issued proposed regulations under Section 707(a)(2)(A) of the Internal Revenue Code of 1986, as amended (the “Code”), covering the...more

8/17/2015 - Business Taxes Fee Waivers IRS Management Fees Partnerships Profits Interests Safe Harbors Significant Entrepreneurial Risk (SER) Treasury

Revised Timeline for Implementing FATCA

Sections 1471 through 1474 of the U.S. Internal Revenue Code (“FATCA”) generally impose a 30% withholding tax on certain payments to a foreign financial institution (“FFI”) unless the FFI has entered into an agreement with...more

7/16/2013 - Bank Accounts Banks FATCA FFI IGAs Internal Revenue Code (IRC) IRS U.S. Treasury

Financial Services Quarterly Report - First Quarter 2013: FATCA: Next Steps for Asset Managers

The U.S. Department of the Treasury (“Treasury”) and the U.S. Internal Revenue Service (“IRS”) released final regulations (“Regulations”) on January 17, 2013 implementing the Foreign Account Tax Compliance Act (“FATCA”).1...more

3/27/2013 - Asset Management Due Diligence FATCA FFI Intergovernmental Agreements IRS U.S. Treasury Withholding Requirements

Significant Changes Made in Final FATCA Regulations

On January 17, 2013, the U.S. Department of the Treasury (“Treasury”) and the U.S. Internal Revenue Service (the “IRS”) released final regulations (the “Regulations”) implementing foreign account reporting provisions of the...more

2/11/2013 - Collateralized Debt Obligations Due Diligence FATCA Foreign Financial Accounts GIIN Intergovernmental Agreements Investment Funds IRS Portal Required Documentation U.S. Treasury Withholding Requirements

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