News & Analysis as of

U.S. Treasury Private Funds

Dechert LLP

Treasury Proposes Investment Advisers AML/CFT Program Rule

Dechert LLP on

Treasury proposed a new rule that would require investment advisers to establish an AML/CFT program and file certain reports, such as Suspicious Activity Reports (SARs), with FinCEN (Proposed Rule). The Proposed Rule...more

Fox Rothschild LLP

Fund Adviser Exemptions Primer– Redux

Fox Rothschild LLP on

I never find it boring to review the investment adviser exemptions for private fund managers. Apparently, I am not the only one since this is a question we frequently field. Initially, private fund manager investment...more

BCLP

The Adviser: A Quarterly Update for Private Fund Advisers

BCLP on

This newsletter discusses recent key guidance releases, regulatory changes, noteworthy news and certain upcoming compliance deadlines. Topics include: - 10 Things You Should Know About Opportunity Zones - ILPA...more

Dechert LLP

IRS Issues Proposed FATCA Regulations

Dechert LLP on

On December 13, 2018, U.S. Department of the Treasury and the Internal Revenue Service released proposed regulations (the “Proposed Regulations”) that would amend the current regulations relating to the Foreign Account Tax...more

Vedder Price

Annual Compliance Obligation Reminders

Vedder Price on

Investment advisers registered with the U.S. Securities and Exchange Commission (“SEC”) or with a state (“Advisers”) as well as commodity pool operators (“CPOs”) and commodity trading advisors (“CTAs”) registered with the...more

Dechert LLP

BEA Proposes Changes to Reporting Requirements for Private Funds

Dechert LLP on

The Bureau of Economic Analysis (BEA), in collaboration with the U.S. Department of the Treasury (Treasury Department) and the Federal Reserve Bank of New York, has proposed changes to certain cross-border investments that...more

Eversheds Sutherland (US) LLP

Sweeping Changes Proposed to Tax Treatment of Related-Party Debt May Impact Private Funds

Recently proposed Treasury regulations under IRC § 385 (the Proposed Regulations) would potentially treat related-party debt, in whole or in part, as equity for U.S. tax purposes. The Proposed Regulations generally apply to...more

Morrison & Foerster LLP

FinCEN Proposes Anti-Money Laundering and Suspicious Reporting Rules for Registered Investment Advisers

On August 25, 2015, the US Treasury Department’s Financial Crimes Enforcement Network (FinCEN) proposed rules that would require registered investment advisers to adopt anti-money laundering (AML) programs and report...more

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