Patrick Fenn

Patrick Fenn

Akin Gump Strauss Hauer & Feld LLP

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FATCA — Final Deadline to Obtain a GIIN for Model 1 IGA FFIs

Under transitional relief, certain non-U.S. investment funds, including Cayman Islands funds, that qualify as foreign financial institutions (FFIs), have been permitted to certify their status under the U.S. Foreign Account...more

12/8/2014 - Deadlines FATCA FFI GIIN IRS

IRS Internal Memorandum Advises That Self-Employment Tax Applies to Profits From an Investment Manager

On September 5, 2014, the Office of Chief Counsel, Internal Revenue Service (IRS) released an internal generic legal advice memorandum advising an IRS field agent that the statutorily provided “limited partner” exception to...more

9/11/2014 - Income Taxes Investment Adviser IRS Self-Employment Tax

Treasury Delays Implementation of Final Expanded Dividend-Equivalent Regulations By Two Years, Keeps Current Four-Factor Test in...

The Department of the Treasury and the Internal Revenue Service (IRS) announced today (available here) that they are delaying the implementation by two years—until January 1, 2016—of final expanded regulations governing the...more

12/5/2013 - Corporate Taxes Dividends Foreign Corporations Income Taxes IRS U.S. Treasury

FATCA Implementation Further Delayed Until July 1, 2014, FFIs Should Finalize Registrations by April 25, 2014

The Internal Revenue Service (IRS) issued Notice 2013-43 (available here), which delays by six months certain of the timelines during which withholding agents and foreign financial institutions (FFIs) will be required to...more

7/17/2013 - Delays FATCA FFI Foreign Banks Grandfathering Rules IGAs IRS U.S. Treasury

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