• Foreign Investor Forms W-8: An update of Forms W-8 on file for non-U.S. investors is generally recommended by December 31, 2018 to ensure that a date of birth (DOB) and non-U.S. taxpayer identification number (Foreign TIN)...more
10/8/2018
/ Asset Management ,
Certifications ,
Common Reporting Standard (CRS) ,
Controlling Person ,
Derivatives ,
FATCA ,
FBAR ,
Filing Deadlines ,
Foreign Investment ,
Form W-8 ,
Gross Proceeds ,
Income Taxes ,
Intergovernmental Agreements ,
Investment Funds ,
Investment Management ,
Investors ,
IRS ,
OECD ,
Reporting Requirements ,
Section 871(m) ,
Swaps ,
Withholding Tax
• The broader application of Section 871(m) has been delayed further until January 1, 2021 and, as a result, investment funds with non-U.S. feeders or investors up the chain should generally expect to incur U.S. withholding...more
9/24/2018
/ Anti-Abuse Rule ,
Broker-Dealer ,
Delays ,
Derivatives ,
Dividend-Equivalent Transactions ,
Equity Investors ,
Exchange-Traded Products ,
Foreign Investment ,
Internal Revenue Code (IRC) ,
IRS ,
Qualified Derivatives Dealers (QDDs) ,
Section 871(m) ,
Swaps ,
Tax Evasion ,
Withholding Tax
In response to perceived abuses in taxpayers’ use of swaps and other derivative transactions (e.g., options, futures or forwards) to avoid withholding tax on U.S. source dividends, Congress added Section 871(m) to the...more
8/18/2017
/ Anti-Abuse Rule ,
Broker-Dealer ,
Delays ,
Derivatives ,
Dividend-Equivalent Transactions ,
Equity Investors ,
Exchange-Traded Products ,
Foreign Investment ,
Internal Revenue Code (IRC) ,
IRS ,
Section 871(m) ,
Swaps ,
Tax Evasion ,
Withholding Tax