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Results: 11-20 of 24

Dodd-Frank Act effect on non-US investment advisers

  • McDermott Will & Emery
  • -
  • USA
  • -
  • November 22 2010

The Dodd-Frank Wall Street Reform and Consumer Protection Act (the Act), enacted on 21 July 2010 and effective with regard to investment advisory registration matters as of 21 July 2011, mandates significant changes to the regulation of offshore (from the United States) investment managers

New developments affect reporting obligations for U.S. interests in non-U.S. private investment funds

  • Schulte Roth & Zabel LLP
  • -
  • USA
  • -
  • March 23 2010

In late February, the Treasury Department (“Treasury”) issued Notice 2010-23 (“Relief Notice”) and Announcement 2010-16 (the “Announcement”), providing additional guidance relating to the filing of Reports of Foreign Bank and Financial Accounts (Form TD F 90-22.1) (“FBAR”) for all years through 2009

Proposed regulations exempt taxpayers from FBAR reporting for interests in offshore private equity and hedge funds until further guidance is issued

  • Proskauer Rose LLP
  • -
  • USA
  • -
  • March 3 2010

On February 26, 2010, the Treasury Department published long-awaited, revised proposed regulations clarifying which taxpayers will be required to file the Report of Foreign Bank and Financial Accounts, Form TD F 90-22

FBARs not currently required for interests in foreign hedge funds or private equity funds

  • Lowenstein Sandler LLP
  • -
  • USA
  • -
  • March 2 2010

The Treasury Department has provided some welcome relief concerning Foreign Bank Account Report (FBAR) filing requirements, although many key issues remain unresolved

FBAR filing not required for interests in offshore private equity and hedge funds for calendar years 2009 and earlier

  • Paul, Weiss, Rifkind, Wharton & Garrison LLP
  • -
  • USA
  • -
  • March 1 2010

Last Thursday and Friday the Internal Revenue Service (the “IRS”) and the Financial Crimes Enforcement Network (“FinCEN”) of the Department of the Treasury issued current guidance and Proposed Regulations covering a number of important issues with respect to the requirement to file Form TD F 90-22.1, Report of Foreign Bank and Financial Accounts (“FBAR”

Foreign Account Tax Compliance Act of 2009 would require additional disclosure by offshore private funds and their advisors

  • Katten Muchin Rosenman LLP
  • -
  • USA
  • -
  • November 6 2009

Representative Charles Rangel and Senators Max Baucus, Richard Neal and John Kerry introduced the Foreign Account Tax Compliance Act of 2009 (Bill) in Congress, which would require U.S. withholding agents to withhold tax on payments of income from U.S. financial assets to “foreign financial institutions” unless such foreign financial institutions comply with certain disclosure obligations; require additional disclosure by U.S. persons with interests in foreign entities, accounts, and passive foreign investment companies; and require disclosure by any advisor who receives more than $100,000 in compensation for aiding a U.S. person in establishing a foreign entity or investing in foreign financial assets, or face penalties

IRS offers additional relief for filing 2008 (and earlier) FBARs

  • Fried Frank Harris Shriver & Jacobson LLP
  • -
  • USA
  • -
  • August 7 2009

We previously advised about significant uncertainties that exist with respect to Form TD F 90-22.1, Report of Foreign Bank and Financial Accounts and related instructions (the “FBAR”) (most notably, with regard to whether US persons who hold interests in offshore hedge funds or offshore private equity funds are required to file FBARs with respect to such interests

Potential IRS reporting requirements for investors in offshore private equity and hedge funds

  • Jones Day
  • -
  • USA
  • -
  • July 23 2009

Recent informal comments by representatives of the U.S. Internal Revenue Service ("IRS") indicate that the IRS may expect U.S. investors in foreign hedge funds and foreign private equity funds to file an annual Report of Foreign Bank and Financial Accounts on Form TD F 90-22.1 (an "FBAR"

IRS announces foreign hedge funds and private investment funds subject to foreign bank and financial accounts (FBAR) reporting

  • Duane Morris LLP
  • -
  • USA
  • -
  • July 21 2009

In June 2009, we reported that the U.S. Department of the Treasury has implemented a Voluntary Disclosure Program (VDP) for taxpayers with offshore assets

Investors face expanded FBAR filing obligation, deadline extended

  • Choate Hall & Stewart LLP
  • -
  • USA
  • -
  • June 30 2009

US investors holding interests in offshore private equity, venture capital and other investment funds may now be required to disclose such interests on the Report of Foreign Bank and Financial Accounts