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ARTICLE · 24 MARCH 2014

FATCA Final Regulations - Update For Cayman And Irish CLO Issuers

Maples Group
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On 20 February 2014 the US Treasury and the IRS released a set of revisions to the US Foreign Account Tax Compliance Act ("FATCA") final regulations (the "FATCA Regulations").

GlobalTax
Alasdair Robertson
Alasdair Robertson
Mark Matthews
Mark Matthews
Scott Macdonald
Scott Macdonald
Nicola Bashforth
Nicola Bashforth
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On 20 February 2014 the US Treasury and the IRS released a set of revisions to the US Foreign Account Tax Compliance Act ("FATCA") final regulations (the "FATCA Regulations"). Such revisions include modifications to the Limited Life Debt Investment Entities ("LLDIE") provisions in the FATCA Regulations. 

Further to our prior client updates on (i) the Cayman Islands Model 1B (non-reciprocal) intergovernmental agreement with the US (the "Cayman IGA"), and (ii) the Irish Model 1A reciprocal intergovernmental agreement with the US (the "Irish IGA" and together with the Cayman IGA, the "IGAs"), this update provides a summary of the latest position for CLO issuers incorporated in the Cayman Islands and Ireland ("CLO Issuers").1 

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