Year-End FATCA Action Items for Investment Funds That Are Sponsored Entities or Have Investors That Are Sponsored …

In order to comply with the U.S. Foreign Account Tax Compliance Act (“FATCA”), certain investment managers chose to sponsor their non-U.S. investment funds, whereby the investment manager (or an affiliate) agreed to perform all FATCA due diligence, withholding, reporting and other requirements on behalf of its sponsored funds.[1] To date, sponsored funds were permitted to rely on the registration of

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