This is the second in a series of Foley Advisers about FATCA, the new U.S. tax regime designed to combat offshore tax evasion by U.S. taxpayers that will go into effect on January 1, 2014. Our prior installment described...more
Yesterday, President Obama issued his Administration’s Fiscal Year 2014 Budget, which includes a proposal to tax carried interests (also known as “performance allocations” or “incentive allocations”) in investment...more
Earlier this year, the IRS announced that U.S. entities that hold interests in “specified foreign financial assets” will not be required to report such interests on IRS Form 8938 until final regulations are issued, and in no...more
U.S. Funds with Only U.S. Investors -
FATCA, the new U.S. tax regime designed to combat offshore tax evasion by U.S. taxpayers, will go into effect on January 1, 2014. As a fund manager, you will be required to ensure...more
On January 2, 2013, President Obama signed into law the American Taxpayer Relief Act of 2012 (the “Act”).
Among its provisions, the Act extends a tax benefit whereby capital gains from the sale or exchange of certain...more