On 8 February, the long-awaited proposed regulations providing guidance on the various provisions under the Foreign Account Tax Compliance Act ("FATCA"), which was enacted as part of the Hiring Incentives to Restore Employment Act of 2010, were issued. The proposed regulations provide guidance on a number of specific implementation issues relevant to the asset management industry, and it is clear that a number of comments received from the industry were incorporated into the regulations. The proposed regulations generally do not, however, delay the existing effective dates for FATCA compliance.
Although these regulations are only proposed, they appear to provide sufficient guidance for fund managers to begin assessing what information gaps exist, determining what systems changes will need to be made, and communicating with their third-party service providers in order to address the looming effective dates of these rules. For more FATCA publications:
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