Proposed Foreign Account Tax Compliance Act: Impact On Non-U.S. Financial Institutions, Intermediaries, And Investment Vehicles

On October 27, 2009, proposed U.S. tax legislation entitled the “Foreign Account Tax Compliance Act of 2009” (the “Bill”) was introduced in both houses of the U.S. legislature and endorsed by the Obama administration[...] If enacted in its current form, the Bill would introduce a number of new provisions that would significantly modify the U.S. withholding tax and information reporting regimes affecting U.S. persons, non-U.S. banks and other financial intermediaries and their affiliates, non-U.S. hedge and private equity funds, and certain other non-U.S. investment structures…

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