Title

House to Consider Bill Containing Carried Interest Proposal, Ban on Bearer Bonds and Updated FATCA Rules
Client Memorandum

Created date

12/9/2009

On December 9, the House of Representatives will consider a bill to extend a variety of expiring tax provisions. As had been expected, the bill will include as revenue raisers a revised version of the “Foreign Account Tax Compliance Act” (“FATCA”) and a revised version of Representative Sander Levin’s proposal to tax income from a service provider’s profits interest in an investment partnership at ordinary rates (the “carry proposal”). We described the highlights of the original FATCA proposal in a memorandum dated October 28, Highlights of Proposed Legislation Aimed at Combating Offshore Tax Evasion, and the previous carry proposal in a memorandum dated April 13, Update on “Carried Interest” Legislation: New Levin Bill. There follows a brief summary of certain proposed changes that the House is considering making to the originally proposed FATCA and carry proposals.

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