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FATCA and IGA: defining investment entities

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FATCA requires some UK entities to register with the IRS and to conduct diligence and reporting on their investors and account holders. Tax practitioners working with investment entities should be wary of inconsistencies between the US regulations and the UK Intergovernmental Agreement and between the UK regulations and guidance notes. They should also be aware of the inconsistencies within the UK guidance notes and numerous unanswered questions.

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