Anthony J. Carbone

IRS and Treasury Release Massive Set of Proposed Regulations on FATCA
Charles R. Bogle,Anthony J. Carbone,Will Cejudo,James Alan Gouwar,Thomas Gray, February 14, 2012
The Internal Revenue Service (the “IRS”) and Treasury have released a comprehensive set of proposed regulations relating to the implementation of the Foreign Account Tax Compliance Act ("FATCA"). The most significant changes made by the proposed regulations are to delay the...

Recommended Annual Review for Hedge Fund and Other Private Fund Managers
Anthony J. Carbone,Jean Cogill,Barry N. Hurwitz,Smriti Kodandapani,Ephraim D. Lemberger,Robert G. Leonard,Michael F. Mavrides,Thomas M. Schiera, November 22, 2011
2011 ushered in a number of significant changes regarding how managers of hedge funds and other private funds are regulated. Many of the changes introduced in 2010 took effect this year and have had a significant impact on the private fund industry. The following is meant to briefly recap some of...

IRS Proposes Regulations Expanding the Definition of a “Notional Principal Contract”
Charles R. Bogle,Anthony J. Carbone,Will Cejudo,James Alan Gouwar,Thomas Gray, September 22, 2011
The IRS has proposed regulations that clarify and expand the definition of what contracts qualify to be treated as notional principal contracts — the typical way swaps are treated for federal income tax purposes. A payment to a non-U.S. person under a swap contract that qualifies as a...