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FATCA: U.S. and Non-U.S. Sector Impact Overviews

Foreign Account Tax Compliance Act (FATCA) sector impact overviews focus on recommended actions to achieve compliance of FATCA provisions for U.S. Withholding Agents (USWA), Foreign Financial Institutions (FFIs), and Non-Financial Foreign Entities (NFFEs).

U.S. Broker/Dealer
In order to be FATCA compliant by January 1, 2014, U.S. broker/dealers would have to undertake substantial work and overcome significant implementation challenges. The impacted broker/dealers should begin designing future state operating models and implementation road maps along with identifying the functionalities of technology systems that will need to be updated.

U.S. and Non-U.S. Private Equity & Hedge Funds
The implication of the FATCA regulations on private equity and hedge funds is significant. Virtually every private equity and hedge fund will have to comply with the regulations because such funds will likely be considered either a U.S. withholding Agent (“USWA”) or a foreign financial institution (‘FFI”) under the rules.

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