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Alternative Market Briefing

US continues making FATCA agreements despite doubts on implementation

Tuesday, July 09, 2013

Bailey McCann, Opalesque New York:

The US continues to make arrangements with foreign governments over the implementation of the Foreign Account Tax Compliance Act (FATCA) despite doubts raised by some in Congress that the IRS has the resources to implement the law. The UK’s tax authority, HMRC, issued regulations at the end of May designed to bring that country into compliance with FATCA. These regulations will be part of that country's Finance Act 2013, and will come into effect later this year. FATCA itself is slated to come into force at the start of 2014, and the US has been busily working to get foreign governments to sign on to one of two tax agreement models.

Those models give each government the opportunity to take on reporting itself as a matter of its tax regime or to rely on the reporting of US persons with some checks. As Opalesque has previously reported, many alternative investment firms where hanging back on their own FATCA compliance awaiting tax agreements in key jurisdictions like the Caymans. Most of those have now been decided and so firms themselves are also working on compliance for this law among others.

According to a client alert from Bingham McCutchen, with the new UK regulations, "dir......................

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