Tax Administration

There is no doubt that the various regulatory changes we have seen in recent years have created a heightened administrative environment for SPV issuers and their investment managers. For example, the implementation of the Dodd Frank Act brought with it significant changes to all IRS international tax forms such as the W-8BEN-E and W-8IMY. What was once a relatively simple one page certification is now an eight page document with the inclusion of very important FATCA classification representations. With increasing scrutiny on SPVs transacting with the US, we have seen our clients applying more frequently to the IRS for an EIN to support additional reporting requirements imposed on managers.