Monday, September 19, 2011

Paris seminar explores impact of new FATCA rules on Investment Funds in Europe

Around 40 fund managers, hedge funds, trust companies and lawyers attended Curtis's Paris seminar last Tuesday, 13 September. The seminar, entitled “Investment Funds: Recent Tax Developments, Understanding FATCA, FBAR and Key Regulations in Europe” brought the European audience up to date with latest developments in the FATCA rules (some of which had taken place within the previous 48 hours). Many of the audience were in Paris for the International Fiscal Association's annual congress, which took place the same week.

New York partners Alan S. Berlin and William L. Bricker, Jr joined Paris based partner Marco A. Blanco for a panel presentation on recent developments in US international taxation. Frankfurt based partner Christian Fingerhut and Milan based partner Fabrizio Vismara drew out the impact of the new rules on investment funds in the European regulations, particularly in Germany and Italy.

Download the presentation materials: Presentation on US tax and investment funds.pdf
Download Curtis speakers' profiles and team information: investment funds and tax seminar - speakers and information.pdf


Friday, September 9, 2011

TIC Form SLT imposes new reporting obligations for cross-border investments that may apply to private funds and private fund managers

The Department of the Treasury and the Federal Reserve Bank recently implemented new Form SLT, which will be part of the Treasury International Capital (TIC) reporting system designed to provide timely information on international capital movements. Form SLT will be used to collect monthly data on cross-border ownership by U.S. and foreign residents of long-term securities for portfolio investment purposes. The reporting panel for the Form SLT consists of all U.S. persons who are U.S.-resident custodians, U.S.-resident issuers of U.S. securities or U.S.-resident end-investors in foreign securities, where for each reporting entity, the consolidated total of all reportable long-term U.S. and foreign securities on the last business day of the reporting month has a total fair market value equal to or more than the exemption level, which is set at $1 billion. All U.S. persons who are U.S.-resident custodians, U.S.-resident issuers or U.S.-resident end-investors and who meet or exceed the reporting threshold must file the Form SLT. Accordingly, certain private funds and private fund managers may be required to filed Form SLT if they satisfy these conditions.

The obligation to report on Form SLT becomes effective on September 30, 2011 with the first filing due by October 23, 2011. The following filing is due by January 23, 2012. Thereafter, Form SLT is required to be filed on a monthly basis.

Link to the Form SLT:

Link to the Form SLT Instructions: