The definition of investment entities under FATCA, under the model IGA and under the UK IGA, regulations, guidance notes varies in important respects. Andrey Krahmal (Temple Tax Chambers) provides a summary of how the rules apply to investment entities most frequently encountered in practice.
Jayne Newton takes a look at the recently signed UK/Isle of Man intergovernmental agreement and its significance
The practical difficulties may be harder than expected to deal with, claims James Coward