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What matters: A review of 2011 and 2012
- Kramer Levin Naftalis & Frankel LLP
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- USA
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- April 1 2013
As you know, the last two years have seen a somewhat improved, but by no means robust, business climate. At the same time, structural shifts in the
Recent developments for the fourth quarter 2011
- Baker & McKenzie
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- Canada, China, Denmark, European Union, France, Germany, Ireland, Italy, Japan, Netherlands, Switzerland, United Kingdom, USA
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- March 15 2012
The end of the year and beginning of a new year is always a busy time for us, as it is for most of our clients
Final FBAR regulations offer some relief for plan sponsors, but filing obligations remain
- McDermott Will & Emery
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- USA
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- April 7 2011
The Treasury Department has issued final regulations concerning the FBAR filings
Dodd-Frank Act effect on non-US investment advisers
- McDermott Will & Emery
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- USA
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- 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
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- USA
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- 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
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- USA
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- 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 PC
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- USA
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- 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
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- USA
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- 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
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- USA
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- 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
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- USA
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- 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
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