A general guide in determining the application of FATCA to non-US funds.
I. What Is FATCA? FATCA refers to the US Foreign Account Tax Compliance Act (contained in Sections 1471 through 1474 of the US Internal Revenue...more
The Internal Revenue Service (the “IRS”) and Treasury Department have proposed regulations (the “Proposed Regulations”) under Section 856 of the Internal Revenue Code providing guidance for analyzing whether non-traditional...more
The US Department of the Treasury recently announced that the United States has signed a “Model 1” intergovernmental agreement (an “IGA”) with respect to the US Foreign Account Tax Compliance Act (“FATCA”) with the Cayman...more
In recent years, there has been a considerable expansion of the types of companies holding non-traditional real estate assets that have elected to become real estate investment trusts for US federal income tax purposes...more
The Cayman Islands government announced on August 13, 2013 that it has concluded negotiations with the US government on a “Model 1” intergovernmental agreement (“IGA”) with respect to the US Foreign Account Tax Compliance Act...more
In recent years, the US Internal Revenue Service has considerably expanded the categories of real estate assets that may be owned by a real estate investment trust (a “REIT”). This expansion of qualifying or “REIT-able”...more