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ARTICLE · 11 FEBRUARY 2014

Drinking GIIN And The IRS' Juice

DMS Governance Ltd
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Like Snoop Dogg, the vast majority of investment managers, directors of hedge funds and private equity funds, plus their service providers and counterparties, including administrators, banks, custodians, prime brokers and other financial institutions, whether foreign (i.e., non-U.S.) or U.S., must soon start sipping on gin and juice before they can be laid back when thinking about their money.

United StatesTax
Peter Stafford
Peter Stafford
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"Rollin down the street, smokin indo, sippin on gin and juice/ Laid back (with my mind on my money and my money on my mind)." — Snoop Doggy Dogg. Nov. 23, 1993.

Like Snoop Dogg, the vast majority of investment managers, directors of hedge funds and private equity funds, plus their service providers and counterparties, including administrators, banks, custodians, prime brokers and other financial institutions, whether foreign (i.e., non-U.S.) or U.S., must soon start sipping on gin and juice before they can be laid back when thinking about their money.

This potent cocktail is the perfect metaphor for the powerful combination of the Global Intermediary Identification Number mixed with the tremendous power or "juice" of the Internal Revenue Service, spawned by the Foreign Account Tax Compliance Act. Like the cocktail, it will deliver more than a few headaches, but this time the hangover will not go away.

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