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Investment Funds Internal Revenue Service Foreign Account Tax Compliance Act

Seward & Kissel LLP

New FATCA Agreement with Switzerland

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The United States and Switzerland jointly announced the conversion of the intergovernmental agreement (“IGA”) from a “Model 2” to “Model 1” agreement. The new IGA will come into effect January 1, 2027, allowing time for...more

Akin Gump Strauss Hauer & Feld LLP

U.S. Withholding Tax and Reporting Action Items for Investment Funds and Asset Managers (Fall 2018)

• Foreign Investor Forms W-8: An update of Forms W-8 on file for non-U.S. investors is generally recommended by December 31, 2018 to ensure that a date of birth (DOB) and non-U.S. taxpayer identification number (Foreign TIN)...more

Akin Gump Strauss Hauer & Feld LLP

Renewal of U.S. FATCA Registration for Certain Investment Funds by Monday, July 31, 2017

Certain non-U.S. investment funds, including Bermuda funds, which qualify as foreign financial institutions (FFI), must enter into a legal agreement (“FFI agreement”) with the U.S. Internal Revenue Service (IRS) to be treated...more

Blank Rome LLP

FATCA Update: Institute of International Bankers Submits Comment Letter on FATCA Regulations

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The Institute of International Bankers (IIB) has submitted a comment letter (available through Bloomberg BNA here; subscription required) to the Internal Revenue Service addressing various issues arising under the FATCA...more

Foley Hoag LLP

FATCA Compliance for Investment Fund Managers, Part Three

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Offshore Master with U.S. and Offshore Feeders - This is the third in a series of Foley Advisers about FATCA, the new U.S. tax regime designed to combat offshore tax evasion by U.S. taxpayers that will go into effect...more

Foley Hoag LLP

FATCA Compliance for Investment Fund Managers Part One

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U.S. Funds with Only U.S. Investors - FATCA, the new U.S. tax regime designed to combat offshore tax evasion by U.S. taxpayers, will go into effect on January 1, 2014. As a fund manager, you will be required to ensure...more

Dechert LLP

Significant Changes Made in Final FATCA Regulations

Dechert LLP on

On January 17, 2013, the U.S. Department of the Treasury (“Treasury”) and the U.S. Internal Revenue Service (the “IRS”) released final regulations (the “Regulations”) implementing foreign account reporting provisions of the...more

Dechert LLP

Financial Services Tax – UK Update from Dechert’s Tax Group - February 2013: FATCA Update – No Duplicate Reporting for Investment...

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Following the execution of an inter-governmental agreement (or “IGA”) with the United States in September 2012 and a consultation exercise which closed in late 2012, HM Revenue & Customs (“HMRC”) recently published draft...more

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