News & Analysis as of

U.S. Treasury Investment Management

Foley Hoag LLP

Treasury Subjects Investment Advisers to Anti-Money Laundering Requirements

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On August 28, 2024, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued its final rule requiring certain investment advisers to implement anti-money laundering (“AML”) compliance...more

Foley Hoag LLP

TIC Form SHL-Reporting of Foreign Holdings of U.S. Securities Due August 30, 2024

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Form SHL is a five-year mandatory benchmark survey filing commissioned by the Department of the Treasury and administered by the Federal Reserve Bank of New York (“FRBNY”) applicable to all U.S.-resident issuers with foreign...more

Seward & Kissel LLP

August 30 Deadline for TIC Form SHL

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Memorandum to our Investment Management Clients and Friends - The Quinquennial Report of Foreign-Resident Holdings of U.S. Securities (“TIC Form SHL”) is a benchmark report used by the U.S. Department of the Treasury to...more

Morrison & Foerster LLP

FinCEN & the SEC: Will the Real RIA and ERA Customers Please Stand Up?

On May 13, 2024, the U.S. Department of the Treasury’s (“Treasury”) Financial Crimes Enforcement Network (FinCEN) and the Securities and Exchange Commission (SEC) issued a joint Notice of Proposed Rulemaking (NPRM) that would...more

Goodwin

Form SHL: What You Need to Know

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The US Department of the Treasury (the Treasury), with the assistance of the Board of Governors of the Federal Reserve System and the Federal Reserve Bank of New York, conducts a mandatory benchmark survey every five years. ...more

Cadwalader, Wickersham & Taft LLP

Treasury Delivers Mother Lode of Tax Reporting Rules to the Crypto Industry’s Doorstep

On August 29, 2023, the IRS published detailed proposed regulations addressing digital asset broker reporting requirements (the “Proposed Regulations”). The Proposed Regulations elaborate on the 2021 changes to the Internal...more

Dechert LLP

U.S. Treasury Implements Significant Changes to TIC SLT Form: Implications for Investment Managers

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Effective for reports as of November 2022 (i.e., those reports due in December 2022) and afterwards, the U.S. Department of Treasury (Treasury) has implemented important and significant changes to the reporting requirements...more

Dechert LLP

U.S. Treasury’s Benchmark TIC SHC Survey and Implications for Investment Managers (UPDATED)

Dechert LLP on

In March 2022, the U.S. Department of the Treasury (Treasury) and the Federal Reserve Bank of New York (FRBNY) will conduct a benchmark survey of U.S. ownership of foreign securities....more

Lowenstein Sandler LLP

Reminder–Form SHC: Report of U.S. Ownership of Foreign Securities Due March 4, 2022

Lowenstein Sandler LLP on

Lowenstein Sandler’s Investment Management Group is pleased to provide you with (i) background information on the purpose and applicability of Form SHC (“Form SHC”); (ii) a summary of its contents; (iii) considerations for...more

Goodwin

Fed Invites Public Comment on Proposed Changes to Durbin Amendment

Goodwin on

In this Issue. The Board of Governors of the Federal Reserve System (Federal Reserve) invited public comment on proposed changes to Regulation II, better known as the Durbin Amendment, regarding network availability for...more

Neal, Gerber & Eisenberg LLP

Fund Managers and Family Offices Get Some Clarity on Carried Interests with Issuance of Proposed Treasury Regulations

On August 14, 2020, the IRS published Proposed Treasury Regulations (the “Proposed Regulations”) under Section 1061 of the Internal Revenue Code to close the “carried interest loop hole” through which managers of investment...more

Goodwin

Financial Services Weekly Roundup: Priming The Pump – Additional Actions To Combat COVID-19

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Priming the Pump. As the COVID-19 outbreak continues, the Board of Governors of the Federal Reserve System (Federal Reserve), consistent with the Coronavirus Aid, Relief, and Economic Security Act (CARES Act), took additional...more

Goodwin

Financial Services Weekly Roundup: The SBA’s New Paycheck Protection Program

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Paycheck Protection Problems. In last week’s Roundup, we discussed the initial guidance issued by the U.S. Department of the Treasury (Treasury) and the Small Business Administration (SBA) on the implementation of the...more

Seyfarth Shaw LLP

[Event] Treasury Issues Final CFIUS Rules: How Are Transactions With Foreign Parties Affected? - February 27th, New York, NY

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This program, co-sponsored by Seyfarth and Kroll, a division of Duff & Phelps, will bring into sharper focus the application of new regulations issued by Treasury on behalf of the Committee on Foreign Investment in the United...more

Vedder Price

Deadline Approaching for Form TIC SHL

Vedder Price on

U.S. issuers (including private investment funds such as hedge, private equity and venture capital funds) must report certain data regarding holdings of their securities by non-U.S. residents to the U.S. Treasury via Form TIC...more

Dechert LLP

U.S. Treasury’s Benchmark TIC SHL Survey and Implications for Investment Managers

Dechert LLP on

In August 2019, the U.S. Department of the Treasury (Treasury) and the Federal Reserve Bank of New York (FRBNY) will conduct a benchmark survey of foreign residents’ holdings of U.S. issuers’ securities. The information will...more

Bass, Berry & Sims PLC

Trump Seeks to Ease Rules for Multiple-Employer Retirement Plans and Required Mandatory Withdrawals

Bass, Berry & Sims PLC on

On August 31, 2018, President Trump signed an executive order authorizing the U.S. Department of Labor (DOL) and the U.S. Department of the Treasury to evaluate expanding access to 401(k) retirement plans. The order is...more

Carlton Fields

Treasury Department Urges SEC to Act on Life Company Products

Carlton Fields on

The U.S. Department of the Treasury published an October 2017 report, "A Financial System That Creates Economic Opportunities — Asset Management and Insurance" in response to President Trump’s Executive Order 13772 on "Core...more

Vedder Price

Investment Services Regulatory Update - November 2017

Vedder Price on

New Rules, Proposed Rules, Guidance and Alerts - SEC STAFF GUIDANCE AND ALERTS - SEC Staff Issues No-Action Letters to Facilitate Cross-Border Compliance with the Research “Unbundling” Provisions of the European...more

Troutman Pepper

Treasury Report Addresses Regulatory Approaches Affecting Investment Companies and Their Advisers

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As required by President Trump’s Executive Order 13772, the U.S. Department of the Treasury issued a report, “A Financial System That Creates Economic Opportunities, Asset Management and Insurance,” addressing the regulatory...more

Dechert LLP

U.S. Treasury’s Benchmark TIC SHC Survey and Implications for Investment Managers

Dechert LLP on

TIC SHC is a mandatory benchmark study commissioned by the Treasury and administered by the FRBNY every five years.3 The survey reviews holdings of foreign portfolio securities – including short- and long-term securities and...more

Morrison & Foerster LLP

MoFo Tax Talk - Volume 8, No. 3

Final and Temporary Dividend Equivalent Regulations Issued – Some Good, Some Bad, And Some Ugly: On September 17, 2015, the Internal Revenue Service (“IRS”) released final and temporary regulations under Section 871(m),...more

Troutman Pepper

The Time to Transfer Entity Interests Is Now - Trust and Estates Update Vol. 2015, Issue 1

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Upcoming IRS regulations may significantly limit and reduce planning opportunities to transfer minority interests in closely held entities to family members and increase the transfer tax cost associated with moving such...more

Pillsbury Winthrop Shaw Pittman LLP

Proposed Regulations Target Management Fee Waivers

In the Federal Register for July 23, 2015, the Treasury Department published proposed regulations regarding the circumstances under which partnership allocations and distributions will be treated as disguised payments for...more

Morgan Lewis

IRS Issues Proposed Regulations Addressing “Fee Waiver” Arrangements

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The proposed regulations may have a significant impact on certain “management fee waiver” arrangements that have become commonplace in the investment management industry....more

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