MFA Comment Letters

Topic: U.S.-based manager

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 […]

Click to expand relevant topics

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,
Results 1 - 2 of 2