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April 17, 2014

Cayman Islands to Enter into a Model 1 Intergovernmental Agreement "IGA"

The Cayman Islands announced on March 15 that it intends to enter into a Model 1 Intergovernmental Agreement (IGA) with the Internal Revenue Service for Foreign Account Tax Compliance Act (FATCA) compliance purposes.

Accordingly, hedge funds and private equity funds that operate in the Cayman Islands will not have to enter into FATCA agreements with the IRS (although they still will have to obtain FATCA identification numbers). In addition, any FATCA reporting required of such funds will be to the Cayman Islands government, which in turn will provide information concerning direct and indirect ownership by US persons to the IRS. The IGA, when finalized, also may exempt certain funds (that are unlikely to have any direct or indirect US investors) from FATCA compliance.

©2014 Katten Muchin Rosenman LLP

About the Author

Robert Loewy, Tax Attorney, Katten Muchin Law firm
Special Counsel

Robert Loewy concentrates his practice in tax planning and litigation.

Robert advises domestic and foreign clients on a broad range of US and international tax issues. His practice is both transactional and advisory, focusing on the taxation of financial instruments and products, hedge funds and private clients. He also has extensive experience in advising clients as to the tax consequences of domestic and cross-border mergers, acquisitions and restructurings.

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