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On February 8, 2012, the Treasury Department released proposed regulations under legislation that requires foreign financial institutions (including foreign banks, brokers, hedge funds and securitization vehicles such as CLOs) to report to the IRS information regarding U.S. account holders
The IRS has issued supplemental guidance regarding recently enacted foreign financial account reporting requirements in the Internal Revenue Code under the Foreign Account Tax Compliance Act ("FATCA"
A private letter ruling ("PLR") issued by the Internal Revenue Service ("IRS") on February 16, 2011, on the equity treatment of closed-end fund liquidity enhanced preferred stock, confirms that the IRS will continue following the principles of expired IRS Notice 2008-55, which allowed closed-end municipal bond funds to refinance traditional auction rate or remarketed preferred stock ("ARPS") with liquidity enhanced preferred stock, such as variable rate demand preferred stock ("VRDP"
The deadline to file FormTD F 90-22.1, the Report of Foreign Bank and Financial Accounts (the “FBAR Form”), with the U.S.Treasury Department with respect to foreign bank, securities or other financial accounts held during the 2008 calendar year is June 30, 2009
