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Email On February 8, the Internal Revenue Service issued proposed regulations that provide guidance on the “FATCA provisions” contained in sections 1471-1474 of the Internal Revenue Code. The purpose of FATCA is to reduce U.S. tax evasion by requiring "foreign financial institutions" and certain other foreign entities to provide information to the IRS about U.S. holders of their debt and equity interests and other "financial accounts," or else be subject to a 30% withholding tax. https://www.cadwalader.com/resources/clients-friends-memos/application-of-proposed-fatca-regulations-to-foreign-investment-vehicles