Tax Law

Recent Posts

FATCA and Foreign Funds
Posted on 3 Mar 2011 by Ivan Mitev

...[A]n article... by Lee Sheppard titled "Danilack Warns Multinationals on FATCA and GRAs" ...reports on deputy commissioner (international) Michael Danilack's views on FATCA and raises some questions... "What if private equity funds... Read More

FATCA, Stop Tax Haven Abuse Act and Monetization Strategies
Posted on 17 Aug 2011 by Ivan Mitev

Had [the Stop Tax Haven Abuse Act] been enacted, [it] would have impacted the investment fund industry in many ways, including the conversion of many foreign "blocker" entities into US corporations. The bill did not get traction but now it is... Read More

Notice 2011-34: The Second Round of FATCA Guidance Is Released
Posted on 19 Apr 2011 by Ivan Mitev

... [Notice 2011-34 FATCA] guidance comes in the form of another voluminous notice... which, in addition... Notice 2010-60, comes to a... possible 100-150 page proposed regulation, counting the preamble. It seems paradoxical... when everybody is talking... Read More

  • Blog Post: FATCA and Foreign Funds

    ...[A]n article... by Lee Sheppard titled "Danilack Warns Multinationals on FATCA and GRAs" ...reports on deputy commissioner (international) Michael Danilack's views on FATCA and raises some questions... "What if private equity funds are making U.S. investments through a foreign holding...
  • Blog Post: Notice 2011-34: The Second Round of FATCA Guidance Is Released

    ... [Notice 2011-34 FATCA] guidance comes in the form of another voluminous notice... which, in addition... Notice 2010-60, comes to a... possible 100-150 page proposed regulation, counting the preamble. It seems paradoxical... when everybody is talking about simplifying the Tax Code. I'd venture...
  • Blog Post: FATCA, Stop Tax Haven Abuse Act and Monetization Strategies

    Had [the Stop Tax Haven Abuse Act] been enacted, [it] would have impacted the investment fund industry in many ways, including the conversion of many foreign "blocker" entities into US corporations. The bill did not get traction but now it is being reintroduced both in the Senate (S.1346 introduced...