FATCA Update: Final Regulations and Cayman IGA Negotiations

May 3, 2013

This memorandum addresses recent developments in the application of the Foreign Account Tax Compliance Act (FATCA) to private investment funds.  Specifically, this memorandum discusses the recently finalized Treasury Regulations interpreting FATCA, the impact of a potential Intergovernmental Agreement between the United States and the Cayman Islands on private investment funds, and steps you should be taking now to ensure that your organization complies with FATCA when it becomes effective on January 1, 2014.