The Final FATCA Regulations: Applications to Foreign Investment Vehicles
David Miller, Jason D. Schwartz and Shlomo Boehm
Cadwalader, Wickersham & Taft LLP
February 2013
I. Introduction
On January 17, 2013, the Internal Revenue Service issued final regulations1that provide guidance on the ‘Foreign Account Tax Compliance Act’ (FATCA) provisions contained in sections 1471-1474 of the Internal Revenue Code2.
