MFA Comment Letters

Topic: Form 1065

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

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