Tax Law

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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

Tags: Michael Danilack , Venture Capital and Hedge Fund Taxation

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

Tags: Notice 2011-53 , Venture Capital and Hedge Fund Taxation , Stop Tax Haven Abuse Act

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

Tags: Private Equity , Venture Capital and Hedge Fund Taxation , Notice 2011-34 , Notice 2010-60

  • Blog Post: FATCA and Foreign Funds

    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 are making U.S. investments through a foreign holding...
    on 3 Mar 2011

  • Blog Post: Notice 2011-34: The Second Round of FATCA Guidance Is Released

    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 about simplifying the Tax Code. I'd venture...
    on 19 Apr 2011

  • Blog Post: FATCA, Stop Tax Haven Abuse Act and Monetization Strategies

    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 being reintroduced both in the Senate (S.1346 introduced...
    on 17 Aug 2011