In This Issue:

- FATCA Update: IRS Releases New Regulations, New Forms, and New IGAs

- No Rule Policy on MLPs

- IRS Introduces New Grandfather Rule for Equity-Linked Instruments Under Section 871(m)

- Rev. Proc. 2014-20: Safe Harbor for Section 108(c)(3)(A)

- FAA 20141001F: Underwriting Costs Must Be Capitalized

- Validus Reinsurance Ltd. v. United States

- Chairman Camp Releases “Discussion Draft” Targeting REITs

- IRS Issues Guidance on Virtual Currency

- MoFo in the News

- Excerpt from FATCA Update: IRS Releases New Regulations, New Forms, and New IGAs:

The first quarter of 2014 has seen a flurry of FATCA activity. Withholding under FATCA is scheduled to take effect beginning July 1, 2014, and before you ask, the IRS has been adamant that there will be no more delays in FATCA implementation. However, this has not stopped speculation among practitioners who hold out hope for another six months to prepare.

The first FATCA milestone of 2014 came on January 1, the first day on which an FFI could finalize its registration with the IRS on the FATCA registration portal. Although the portal has been live since August 19, 2013,3 information input by foreign financial institutions (“FFIs”) in 2013 was not regarded as final.