MFA Comment Letters

Topic: PFICs

MFA Letter on PFIC Reporting03.27.14


On March 28, MFA submitted a letter to the IRS encouraging the IRS to exclude funds that mark their assets […]

MFA Comments to IRS on Application of FBAR to Private Investment Funds and Related Issues10.05.09


MFA submitted a letter to the IRS in response to IRS Notice 2009-62, which requests comments and recommendations concerning the […]

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Topics: Internal Revenue Service IRS, private investment funds, Reports of Foreign Bank and Financial Accounts, FBAR, hedge funds, private equity funds, Department of the Treasury, Financial Crimes Enforcement Network, FinCEN, filing obligation, foreign financial account, banks, publicly-held companies, non-public companies, chief financial officer, U.S.-based manager, Internal Revenue Code, FIRPTA, effectively connected income, financial institutions, foreign financial agencies, private sector, signatory authority, covered foreign financial account, commingled fund, Corporation, partnership, mutual funds, non-U.S. hedge fund, non-U.S. private equity fund, open-ended mutual funds, redemption terms, redemption policy, liquidity, financial accounts, New York State Bar Association, bank account, securities account, Lock-up, Tax Section of the New York State Bar Association, Neal S. Wolin, Michael Mundaca, Douglas H. Shulman, James H. Freis, third party transfers, broker-dealer, Passive Foreign Investment Companies, PFICs, PFIC shareholder filing requirements, Form 8621, Form 926, foreign corporations, Form 5471, Form 8865, U.S. tax return, Form 1065, non-U.S. hedge funds, money laundering, other authority, financial interest, master fund, hedge fund manager, Deferred Fees, hedge fund management companies, foreign prime brokerage, officer, partner, Investment Fund Managers, portfolio manager, investment officer, investment fund management company, Other Account Authority, Workbook on the Report of Foreign Bank and Financial Accounts, shareholders, investors, non-U.S. investors, primary owner, United States Person, domestic partnership, domestic corporation, domestic estate or trust, persons in and doing business in the United States, domestic taxpayers, safe harbor, U.S.-based managers,
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