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Topic: Financial Crimes Enforcement Network

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,

MFA Comments to Regulators on Application of FBAR Requirements to Private Investment Funds08.03.09


MFA submitted a letter to Treasury, the IRS and FinCEN on FBAR compliance concerns, requesting that Treasury and the IRS […]

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Topics: Internal Revenue Service IRS, Financial Crimes Enforcement Network, FinCEN, FBAR, private investment funds, Report of Foreign Bank and Financial Accounts, TD F 90-22.1, hedge funds, Tax Section of the New York State Bar Association, NYSBA Letter, financial account, Announcement 2009-51, filing requirement, non-compliance penalties, taxpayer, mutual fund, open-end company, shareholders, Department of the Treasury, Schulte Roth & Zabel LLP,

MFA Letter to IRS Regarding Compliance Issues for Private Investment Funds Filing a Foreign Bank and Financial Accounts Report05.13.09


MFA submitted a letter as a follow up to its meeting on April 7 with officials from the IRS to […]

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Topics: FBAR Requirements private investment funds, Internal Revenue Service, IRS, Foreign Bank and Financial Accounts Reports, hedge funds, prior submissions, Patton Boggs LLP, Office of Chief Counsel, regulations, covered financial accounts, U.S. tax-exempt investors, master-feeder structures, domestic feeder fund, group filings, Form TD 90-22.1, cost-efficient, Fund Managers, compliance, adverse guidance, Glen Kirkland, IRS Reports Clearance Officer, OMB No. 1545-2038, limited liability companies, signature authority, taxpayer identification number, banks, publicly-traded corporations, tax-exempt organization, SRZ, Partnerships, bonds, notes, stock certificates, equity interest, John G. Gaine, Don Carbaugh, Financial Crimes Enforcement Network, FinCEN, United States Department of the Treasury, William Langford, federal tax return, Form TDF 90-22.1, Detroit Computing Center of the Internal Revenue Service, private equity, domestic limited partnerships, domestic limited liability companies, flow through, brokerate accounts, foreign currencies, foreign securities, interpretive guidance, general definitions, derivatives, savings, demand, checking, deposit, mutual fund, illiquid, lock-up periods, tax forms, Form 990, Form 990-PF, Form 5500, Form 1040, schedule B, Question 7a, Form 1065, Question 9, Form 1120, Schedule N, Questioon 6a, AML program rule, pooled interest, control the disposition, Form TD F 90-22, Betty Santangelo, Nancy Rose, Carl E. Kennedy, Don Moorehead, commodity trading advisors, commodity pool operators, legislators, President's Working Group on Financial Markets, PWG, Side-by-Side Structure, board directors, filing exception, FBAR, Schulte Roth & Zabel LLP, federal register,
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