Roger Wise

Roger Wise

K&L Gates LLP

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New Tax Guidance Would Simplify Rules for Shareholders of Institutional Money Market Funds

On July 23, 2014, the Securities and Exchange Commission (SEC) adopted final rules governing the structure and operation of money market funds (SEC MMF Reform Rules). See our client alert entitled “SEC Adopts Floating-NAV and...more

8/4/2014 - Final Rules Floating NAV IRS LiquidAlts Liquidity Fees MMF Money Market Funds Redemption Gates SEC Shareholders Wash Sale Rules

FATCA is Coming

At the end of May 2014, a bill was introduced to the Australian Federal Parliament to give effect to the United States' Foreign Account Tax Compliance Act (FATCA) and the intergovernmental agreement which was executed by...more

6/24/2014 - Australia FATCA FATCA Timeline FFI Intergovernmental Agreements IRS

Allocation of FATCA Withholding Risk in Financial Transactions Outside the United States

The U.S. Treasury Department has delayed implementation of FATCA once again. However, this delay may be the last, and a phased implementation of FATCA is scheduled to begin on July 1, 2014. FATCA introduces the potential for...more

10/23/2013 - Extraterritoriality Rules FATCA FFIs International Tax Issues U.S. Treasury Withholding Requirements

The New World Wide Web: FATCA Inspires a Global Effort to Fight Tax Evasion

The rapid evolution of the Foreign Account Tax Compliance Act (“FATCA”) from a U.S. driven effort to crack down on U.S. offshore tax evaders into an information reporting mechanism being considered for adoption throughout the...more

6/28/2013 - Due Diligence EU European Commission FATCA Intergovernmental Agreements OECD Offshore Funds Reporting Requirements Tax Evasion Withholding Requirements

Tax Reform – The Next Installment: Reforming the Taxation of Financial Instruments

After the fiscal cliff deal failed to include a framework for comprehensive tax reform, many in Washington predicted that the momentum for tax reform would wither away. Although Congress has many important issues on its...more

1/31/2013 - American Taxpayer Relief Act Bonds Derivatives Discussion Draft FIFO Financial Instruments Fiscal Cliff Harvesting Losses Hedge Funds Tax Reform Ways and Means Committee

FATCA Regulations Finally Arrive: A First Look

On January 17, 2013, the U.S. Treasury Department (“U.S. Treasury”) and the Internal Revenue Service (“IRS”) released long-awaited final regulations on the Foreign Account Tax Compliance Act (“FATCA”). The final regulations...more

1/23/2013 - FATCA FFI Foreign Banks Foreign Financial Accounts Intergovernmental Agreements IRS NFFE

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