Historical Comment Letters
(October 31, 1997 - December 31, 2021)
The Association of Global Custodians has issued public commentary in past years on a wide variety of regulatory and market structure issues in many jurisdictions. Some of the relevant jurisdictions and topics are set forth below.
Asia: Regulations and Market Structure
India
Letter to the Chief General Manager-in-Charge, Reserve Bank of India and Mr. S. Ramann, Securities and Exchange Board of India, regarding Documentation Requests from Local Custodians to meet local Anti-Money Laundering and Know Your Customer (KYC) Due Diligence Requirements, April 27, 2011
Letter to P.R. Ravimohan and B. Mahapatra, Reserve Bank of India, regarding Irrevocable Payment Commitments, October 22, 2010
Letter to Jeevan Sonparote, SEBI, regarding FII Submissions regarding PCC, MCV or SPC Structure; Request for a Brief Delay in Enforcement of the Filing Deadline, September 23, 2010
Letter to Jeevan Sonparote, SEBI Bhavan, regarding Margining of Equity Trades on T+0, July 16, 2010
Letter to Anand Sinha, Department of Banking Operations and Development and Jeevan Sonparote, SEBI Bhavan, regarding IPCs Issued by Bank Custodians to Securities Exchanges, July 9, 2010
Letter to Shri C.B. Bhave, Chairman, Securities and Exchange Board of India ("SEBI"), regarding: Potential T+0 Settlement Pre-payment Requirements for Foreign Institutional Investors, May 19, 2008
Letter to Shri C.B. Bhave, Chairman, Securities and Exchange Board of India ("SEBI"), regarding: New Margin Requirements for Foreign Institutional Investors, April 14, 2008
Indonesia
Philippines
Canada: Regulatory Issues
Letter to John Stevenson, Secretary, Ontario Securities Commission, and Claude St. Pierre, Secretary, Commission des Valeurs mobilieres due Quebec, regarding Proposed Amendments to National Instruments 81-102 & Companion Policy 81-102 CP, May 3, 2000
Letter to Daniel P. Iggers, Secretary, Ontario Securities Commission, and Claude St. Pierre, Secretary, Commission des Valeurs mobilières du Quèbec, regarding: Proposed Amendments to National Instrument 81-102 & Companion Policy 81-102 CP, June 18, 1999
Letter to Daniel P. Iggers, Secretary, Ontario Securities Commission, and Jacques Labelle, General Secretary, Commission des Valeurs mobilières du Quèbec, regarding: Proposed Amendments to National Instrument 81-102 & Companion Policy 81-102 CP, October 31, 1997
China: Regulatory Issues
Letter to Dr. Sun Jie, Director General, China Securities Regulatory Commission, regarding: Qualified Foreign Institutional Investor Program, January 28, 2003
Letter to Mr. Zheng Yang, Deputy Director, State Administration of Foreign Exchange, regarding: Qualified Foreign Institutional Investor Program, January 28, 2003
Committee on Payment and Settlement Systems/International Organization of Securities Commissions (CPSS-IOSCO)
Letter to Secretariat of the Basel Committee on Banking Supervision, Bank for International Settlements, regarding Consultative Document - Revisions to the Standardized Approach for Credit Risk, March 27, 2015
Letter to Secretariat of the Basel Committee on Banking Supervision, Bank for International Settlements, regarding Consultative Document - Revised Basel III Leverage Ratio Framework and Disclosure Requirements, September 24, 2013
Letter to Committee on Payment and Settlement Systems and the International Organization of Securities Commissioners ("CPSS-IOSCO"), regarding the CPSS-IOSCO Consultative Report - Principles for Financial Market Infrastructures, July 29, 2011
Letter to the Secretariat to the CPSS-IOSCO Joint Task Force on Securities Settlement Systems Bank for International Settlements, regarding: Recommendations for Securities Settlement Systems: Report of the CPSS-IOSCO Joint Task Force on Securities Settlement Systems, April 30, 2001
Depository Information-Gathering Project
In response to Investment Company Act Rule 17f-7, the Association of Global Custodians conducts its annual exercise, the Depository Information-Gathering Project, to gather information necessary to meet its compliance objections under the rule.
18th Annual DIGP (2017-2018)
17th Annual DIGP (2016-2017)
16th Annual DIGP (2015-2016)
15th Annual DIGP (2014-2015)
14th Annual DIGP (2013-2014)
Letter to Soraya Belghazi, Secretary General, European Central Securities Depositories Association, regarding WFC Single Disclosure Project, May 3, 2013
13th Annual DIGP (2012-2013)
12th Annual DIGP (2011-2012)
11th Annual DIGP (2010-2011)
10th Annual DIGP (2009-2010)
9th Annual DIGP (2008-2009)
Letter to ACG, ACSDA, ECSDA and AMEDA, regarding Disclosure Framework Development, November 7, 2008
8th Annual DIGP (2007-2008)
7th Annual DIGP (2006-2007)
Letter to Joel Merere, Chief Executive Officer, Euroclear France, S.A., regarding 2006-2007 Depository Information-Gathering Project, October 26, 2006
Letter to Sonia Hsieh, Manager, International Affairs Business, Taiwan Securities Central Depository, regarding 2006-2007 Depository Information-Gathering Project, October 6, 2006
Letter to Mohamed Abd El Salam, Deputy Chairman and Managing Director, Misr for Clearing, Settlement & Central Depository, regarding 2006-2007 Depository Information-Gathering Project, October 6, 2006
Letter to Fernando Yanez, Chief Executive Officer, Deposito Central de Valores, regarding 2006-2007 Depository Information-Gathering Project, October 6, 2006
6th Annual DIGP (2005-2006)
5th Annual DIGP (2004-2005)
2004-2005 Depository Information-Gathering Project: Sample Questionnaire
4th Annual DIGP (2003-2004)
2003-2004 Depository Information-Gathering Project: Sample Questionnaire
3rd Annual DIGP (2002-2003)
2002-2003 Depository Information-Gathering Project: Sample Questionnaire
2nd Annual DIGP (2001-2002)
1st Annual DIGP (2000)
Eastern Europe
Romania
European Union: Regulatory Issues
AIFMD Press Communications
Clearing & Settlement
Letter to Kathleen Holemans (Euroclear Bank) and Russell Callaway (Clearstream Banking), regarding ISMAG, March 21, 2012
Letter to Pierre Francotte (Euroclear S.A.) and Jeff Tessler (Clearstream) regarding ICSD Payment Reversals, October 20, 2009
Letter to the European Central Bank, regarding the Initial Public Consultation, 1 September 2008, on the Eurosystem Single Interface ("ESI"), November 26, 2008
Letter to Jean-Michel Godeffroy, Director General, Payment Systems and Market Infrastructure, European Central Bank ("ECB"), regarding ECB's Public Consultation Papers on T2S User Requirements and the T2S Economic Impact, April 1, 2008
Letter to Dr. Luis Correia da Silva, Oxera Consulting, Ltd., conveying the Association's Views regarding Oxera's Methodology and Assumptions on the Industry-Wide Public Initiative Undertaken for the European Commission, January 28, 2008
Letter to Jean-Michel Godeffroy, Director General, Payment Systems and Market Infrastructure, European Central Bank, June 26, 2007
Letter to Mr. Mario Nava, European Commission, regarding Comments on the Code of Conduct for Clearing and Settlement, December 14, 2006
Letter to Mr. Mario Nava, European Commission, regarding Comments on the Draft Document on Post-Trading, September 22, 2006
Letter to Mr. Mario Nava, European Commission, regarding Comments on the Draft Working Document on Post-Trading, June 30, 2006
Letter to DG Competition, regarding Comments on the May 25, 2006 Consultative Paper, "Competition in EU Securities Trading and Post-Trading", June 30, 2006
Letter to Commissioner Charles McCreevy, Member of the European Commission, regarding Association Views Regarding Cross-Border Clearing and Settlement in Europe and the Commission's Regulatory and Legislative Assessment, March 31, 2006
Letter to Jean -Michel Godeffroy, Director General, Payment Systems, European Central Bank and Eddy Wymeersch, Chairman, Banking and Finance Commission, regarding: Public Statement -- Follow-up Work by the ESCB/CESR Joint Working Group, September 13, 2005
Letter to DG MARKT24 G4, European Commission, regarding: Comments on Shareholder Rights Consultation Document of the Services of the Internal Market Directorate General, December 16, 2004
Letter to DG Competition, European Commission, regarding: Comment on "Overview of EU25 securities trading, clearing, central counterparties, and securities settlement", November 22, 2004
Letter to DG MARKT G1, European Commission, regarding: Communication from the Commission to the Council and the European Parliament - Clearing and Settlement in the European Union - the way forward, July 29, 2004
Letter to Jean-Michel Godeffroy, Director General, European Central Bank, regarding: Revised ESCB-CESR Standards for Securities Clearing and Settlement in the European Union, June 21, 2004
Letter to Arthur Docters van Leeuwen, Chairman, Committee of European Securities Regulators, regarding: Additional Time Needed to Develop Commentary and Presentations Regarding the Revised Standards for Clearing and Settlement Systems in the European Union, May 17, 2004
Letter to Jean -Michel Godeffroy, Director General, Payment Systems, European Central Bank and Eddy Wymeersch, Chairman, Banking and Finance Commission, regarding: Fair Opportunity to Prepare Commentary and Organize Presentations in Connection with the Issuance of Revised Standards or the Scheduling of Consultative Hearings, April 16, 2004
Letter to Jean-Michel Godeffroy, Director General, Payment Systems, European Central Bank, regarding: Association Views on the ESCB-CESR Standards -- Standards for Securities Clearing and Settlement Systems in the European Union, February 23, 2004
Letter to Frits Bolkestein, European Commissioner for Internal Market, Regarding Anticipated Commission Communication Regarding Clearing and Settlement Issues -- Standards for Securities Clearing and Settlement Systems in the European Union, February 17, 2004
Letter to Elias Kazarian, Secretariat, European Central Bank, regarding: Executive Summary and Chart summarizing Association comments to ESCB-CESR -- Standards for Securities Clearing and Settlement Systems in the European Union, November 19, 2003
Letter to Jean-Michel Godeffroy, European Central Bank, and Eddy Wymeersch, Banking and Finance Commission, regarding: Comment on the Standards Report and Scope Statement -- Standards for Securities Clearing and Settlement Systems in the European Union, October 31, 2003
Letter to Jean-Michel Godeffroy, European Central Bank, and Eddy Wymeersch, Banking and Finance Commission, regarding: Request for Comment on Consultative Report -- Standards for Securities Clearing and Settlement Systems in the European Union, October 1, 2003
Letter to DG MARKT F2, European Commission, regarding: Communication From the Commission to the Council and the European Parliament on Clearing and Settlement in the European Union, October 1, 2002
Letter to Christoph Crüwell, Secretariat, Committee of European Securities Regulators and Elias Kazarian, European Central Bank, regarding: Joint Work of the European System of Central Banks and the Committee of European Securities Regulators in the Field of Clearing and Settlement, May 23, 2002
Commission
Letter to Maria Teresa FABREGAS FERNANDEZ, European Commission, regarding European Commission's MiFID II/MiFIR Proposals, October 12, 2012
Letter to Jonathan Faull, European Commission, regarding the European Commission's letter of May 30th to the Association - AIFMD Level 2 Issues, June 25, 2012. The AGC's reply letter and the underlying, referenced communication from Jonathan Faull were elements in a series of communications between the AGC and European Commission officials concerning AIFMD L2
Letter to Martin Foelsch, Permanent Representation of Germany to the European Union, regarding Commission Proposal for a Directive amending Directive 97/9/EC of the European Parliament and of the Council on Investor Compensation Schemes, April 7, 2011
Letter to Patrick Pearson, European Commission, regarding Public Consultation - Central Securities Depositories and the Harmonization of Certain Aspects of Securities Settlement in the European Union, March 7, 2011
Response to Consultation Paper on the UCITS Depositary Function and on the UCITS Managers' Remuneration, January 31, 2011
Response to the European Commission Consultation - Legislation on Legal Certainty of Securities Holding and Dispositions, January 21, 2011
Letter to the European Commission Services - DG Market, regarding Commission Services (DG MARKT) Consultation Paper on the UCITS Depositary Function, September 2, 2009
Cross Border Voting
European Insurance and Occupational Pensions Authority
European Securities and Markets Authority
Letter to European Commission and ESMA, regarding UCITS V, AIFMD and CSD Regulation: Treatment of Central Securities Depositories, April 4, 2016
Letter to Richard Stobo, The European Securities and Markets Authority, regarding AIFMD Implementation Issues, April 26, 2013
Letter to The European Securities and Markets Authority, regarding Association Comments on ESMA's Consultation paper, "Draft technical advice to the European Commission on possible implementing measures of the Alternative Investment Fund Managers Directive in relation to supervision and third countries", 23 August 2011 - ESMA 2011/270, September 23, 2011
Letter to The European Securities and Markets Authority, regarding Association Comments on ESMA's Consultation paper, "Draft technical advice to the European Commission on possible implementing measures of the Alternative Investment Fund Managers Directive", 13 July 2011 - ESMA 2011/209, September 12, 2011
Letter to Richard Stobo, The European Securities and Markets Authority, regarding CESR Call for Evidence Concerning Implementing Measures on the Alternative Investment Fund Managers Directive ("AIFMD"), January 14, 2011
Offshore Fund Processing
Parliament and Council
Letter to Dr. Kay Swinburne, Member of the European Parliament, Parlement européen, regarding Proposal for a Regulation on Improving Securities Settlement in the EU and on CSDs, June 27, 2012
Letter to Jean-Paul Gauzes, Member of the European Parliament/Rapporteur, Dolores Duran Bono, Office of the European Council President and Ugo Bassi, European Commission, regarding Custodians' Continuing Concerns about Draft AIFMD Provisions, February 19, 2010
Letter to Frederick Reinfeldt, President of the European Council, regarding Proposed Re-draft of Article 17 - Alternative Investment Fund Managers Directive, December 2, 2009
Letter to Frederick Reinfeldt, Prime Minister of Sweden, President of the European Council, regarding Proposal for a Directive of the European Parliament and of the Council on Alternative Investment Fund Managers [2009/0064(COD)]; Provisions on Depositaries, July 3, 2009
Transparency Directive
Group of Thirty: Global Clearance and Settlement
Global Clearance and Settlement
Letter to John G. Walsh, Executive Director, The Group of Thirty, regarding: Monitoring Process for G30 Recommendations, May 3, 2004
Letter to John G. Walsh, Executive Director, The Group of Thirty, regarding: Group of Thirty Recommendations Regarding Global Clearance and Settlement, April 7, 2003
Tax
Hague Conference on Private International Law - Indirectly Held Securities
Letter to Christophe Bernasconi, First Secretary, the Permanent Bureau, Hague Conference on Private International Law, regarding: Proposed Convention on the Law Applicable to Proprietary Rights in Indirectly Held Securities - Comments on Article 4 as Set Forth in Preliminary Document No. 16 (September 2002), October 23, 2002
Letter to Christophe Bernasconi, First Secretary, the Permanent Bureau, Hague Conference on Private International Law, regarding: Proposed Convention on the Law Applicable to Proprietary Rights in Indirectly Held Securities - Article 4 of Preliminary Document No. 13 (May 2002), May 15, 2002
Letter to Christophe Bernasconi, First Secretary, the Permanent Bureau, Hague Conference on Private International Law, regarding: Comments on the Preliminary Draft Convention on the Law Applicable to Certain Rights in Respect of Securities Held with an Intermediary, March 15, 2002
Letter to Christophe Bernasconi, First Secretary, the Permanent Bureau, Hague Conference on Private International Law, regarding: Proposed Convention on the Law Applicable to Proprietary Rights in Indirectly Held Securities, October 31, 2001
Hong Kong: Mandatory Provident Fund Schemes
Letter to Salumi Chan, Clerk to Subcommittee, Subcommittee on Mandatory Provident Fund Schemes Ordinance, regarding: Mandatory Provident Fund Schemes (General) Regulation, April 21, 2000
Letter to Raymond Tam, Executive Director (Service Supervision), Mandatory Provident Fund Schemes Authority, regarding: Provisions of the Mandatory Provident Fund Schemes (General) Regulation Governing Custody of Scheme Assets, December 8, 1999
Israel
Middle East & Africa
Bahrain
Nigeria
National Association of Insurance Commissioners (NAIC)
Letter to the Honorable Kathleen Sebelius, Chair, NAIC Executive Committee, and the Honorable John Oxendine, Chair, NAIC Reinsurance Task Force, National Association of Insurance Commissioners, regarding: Proposed Amendments to Section 7E and 10B of the Credit for Reinsurance Model Regulation, June 6, 2001
Letter to Julie Gann, National Association of Insurance Commissioners, regarding: Proposed Amendment to Section 2.B(15) on the Model Regulation on the Use of Clearing Corporations and the Federal Reserve Book-entry System By Insurance Companies, May 11, 2001
Letter to Annette Knief, Financial Services Manager, National Association of Insurance Commissioners, regarding: Proposed Amendment to Section 2.B(15) on the Model Regulation on the Use of Clearing Corporations and the Federal Reserve Book-entry System By Insurance Companies, March 15, 2001
Russia
Securities and Exchange Commission (SEC) - Letters to the U.S. SEC regarding various rule proposals
Investment Company Act Rule 17f-4
Letter to C. Hunter Jones, Assistant Director, Office of Regulatory Policy, Division of Investment Management, S.E.C., regarding: Clarification of Rule 17f-7 Pursuant to Recent Amendments to Rule 17f-4, February 27, 2003
Letter to Jonathan G. Katz, Secretary, S.E.C., regarding: File No. S-7-22-01/Investment Company Act Release No. 25266 (November 15, 2001) -- Custody of Investment Company Assets With A Securities Depository, May 24, 2002
Letter to Jonathan G. Katz, Secretary, S.E.C., regarding: File No. S-7-22-01/Investment Company Act Release No. 25266 (November 15, 2001) -- Custody of Investment Company Assets With A Securities Depository, February 4, 2002
Letter to C. Hunter Jones, Assistant Director, Office of Regulatory Policy, Division of Investment Management, S.E.C., regarding: Rule 17f-4 Review/Information Regarding Rule 17f-7 Compliance Costs, October 17, 2001
Letter to Robert E. Plaze, Associate Director, Office of the Associate Director (Regulation), Division of Investment Management, S.E.C., regarding: Review of Rule 17f-4, December 7, 2000
Investment Company Act Rule 17f-5
Letter to Michael E. Bartell, Associate Executive Director, Office of Information Technology, S.E.C., regarding: Request for Comments Regarding Information Collection Requirements Under Rule 17f-5 and Rule 17f-7, June 28, 2002
Letter to Paul F. Roye, Director, Division of Investment Management, S.E.C., regarding: Treatment of Securities Depositories under Rule 17f-5, April 7, 1999
Letter to Paul F. Roye, Director, Division of Investment Management, S.E.C., regarding: Revised Joint Proposal Regarding Rule 17-f, February 26, 1999, [Submitted Jointly with the Investment Company Institute]
Letter to Barry P. Barbash, Director, Division of Investment Management, S.E.C., regarding: Evaluation of Depositories under Amended Rule 17f-5, June 30, 1998, [Submitted Jointly with the Investment Company Institute]
Letter to Douglas J. Scheidt, Chief Counsel, Office of Associate Director (Chief Counsel), Division of Investment Management, S.E.C., regarding: Request for Interpretive Advice Concerning the Application of Investment Company Act Rule 17f-5(c) to Certain Depositories, December 11, 1997
Investment Company Act Rule 17f-7
Letter to C. Hunter Jones, Assistant Director, Office of Regulatory Policy, Division of Investment Management, S.E.C., regarding: Clarification of Rule 17f-7 Pursuant to Recent Amendments to Rule 17f-4, February 27, 2003
Letter to Michael E. Bartell, Associate Executive Director, Office of Information Technology, S.E.C., regarding: Request for Comments Regarding Information Collection Requirements Under Rule 17f-5 and Rule 17f-7, June 28, 2002
Rule 206(4)-2
Securities Transaction Settlements
Singapore: Guidelines for Custody Arrangements for Insurance Fund Assets
Tax Issues
Austria
Brazil
Canada
Colombia
Denmark
Depository Trust Corporation
European Union Institutions
Letter to the European Commission regarding Public Consultation on Cross-Border Distribution of Investment Funds, November 15, 2016
Letter to the European Commission, Directorate-General for Taxation and Customs Union, regarding Consultation on tax problems faced by EU citizens when active across borders within the EU, July 3, 2014
Letter to Commissioner Algirdas Šemeta, European Commission, regarding Financial Transaction Tax, January 9, 2013
Letter to the European Commission (sent jointly with the AGC, BBA and AFME), regarding Consultation on Taxation Problems That Arise When Dividends are Distributed Across Borders to Portfolio and Individual Investors and Possible Solutions, April 28, 2011
Letter to Frederica Liberatore, European Commission, regarding Custodian Working Group Executive Briefing Paper: Outstanding Italian Tax Refunds -- Points for Discussion, April 11, 2011
Finland
France
Letter to Madame Maylis COUPET, Chef du Bureau Epargne et Marché financier and Monsieur Antoine MAGNANT, Direction de la Législation Fiscale, regarding French Financial Transaction Tax, July 13, 2012
Letter to Benedetta A. Kissel, Esq., Deputy International Tax Counsel (Strategic Programs) U.S. Department of the Treasury, regarding: U.S.-France Income Tax Treaty Issue, August 27, 2007
Letter to M. Vincent Mazauric, Direction de la Legislation Fiscale, regarding: French Tax Relief Issues for Non-Individual Beneficiaries, February 10, 2004
G30
Greece
India
Indonesia
Ireland
Letter to Mr. Gary Palmer, Chief Executive, Dublin Funds Industry Association, regarding Inconsistent Global Tax Treatment of Irish Undertakings for Collective Investment in Transferable Securities, March 27, 2006
Letter to Ms. Marie Hurley and Ms. Susan Cummins, Direct Taxes, Interpretation and International Division, Irish Revenue Commissioners, regarding: Follow-Up on the Inconsistent Global Tax Treatment of Irish UCITs, June 28, 2005
Letter to Ms. Marie Hurley and Ms. Susan Cummins, Direct Taxes, Interpretation and International Division, Irish Revenue Commissioners, regarding: Inconsistent Global Tax Treatment of Irish UCITs, June 4, 2004
IRS
Letter to Internal Revenue Service regarding Form 8802, Application for Certification of U.S. Residency, March 30, 2018
Letter to Internal Revenue Service regarding Temporary Regulations Requiring Foreign TIN and Date of Birth Information on Form W-8BEN, April 5, 2017
Letter to Internal Revenue Service regarding Proposed Regulations on the Automatic Extension of Time to File Form 1042-S under Temporary Treasury Regulation section 1.6081-8T, January 21, 2016
Letter to Commissioner John Koskinen, Internal Revenue Service, et al., regarding Section 1441 Withholding Procedures for Certain Distributions to Which Section 302 Applies, December 9, 2015
Letter to John Sweeney, Internal Revenue Service, regarding Proposed FATCA FAQ on Validity of Print-outs of Electronically Signed Forms W-8 and W-9, May 27, 2015
Letter to John Sweeney, Internal Revenue Service, regarding Proposed FATCA FAQ for Umbrella Fund/Sub-Fund Issue, December 24, 2014
Letter to Ronald Gootzeit, Internal Revenue Service, regarding Reimbursement/Set-Off Procedure under Section 1446, September 30, 2014
Letter to Yvette Lawrence, Internal Revenue Service, regarding Comments on Form 8802 (Application for United States Residency Certification), May 16, 2013
Letter to John Sweeney, Internal Revenue Service and Michael H. Plowgian, United States Treasury, regarding Overlap between FATCA Reporting under Chapter 4 and US Payor Reporting under Chapter 61 of the Internal Revenue Code, November 30, 2012
Letter to John Sweeney, Internal Revenue Service and Michael H. Plowgian, United States Treasury, regarding Follow-Up to July 19, 2012 Meeting on Proposed FATCA Regulations under Sections 1471-1474 of the Internal Revenue Code, September 7, 2012
Letter to John Sweeney, Internal Revenue Service, regarding Comments on Proposed FATCA Regulations under Sections 1471-1474 of the Internal Revenue Code, April 30, 2012
Letter to Messrs. Mark E. Erwin and D. Peter Merkel, Internal Revenue Service, regarding Comments on Temporary Dividend Equivalent Regulations under Section 871(m) of the Internal Revenue Code, March 29, 2012
Letter to Michael Danilack, Internal Revenue Service, regarding Association of Global Custodians: Request for Competent Authority Assistance Under Article 25 of United States - Italy Income Tax Treaty, February 8, 2011
Letter to Internal Revenue Service, regarding Comments on Notice 2010-60 and on Foreign Account Tax Compliance Act (FATCA) Provisions of the Hiring Incentives to Restore Employment (HIRE) Act, November 29, 2010
Letter to Internal Revenue Service and the U.S. Department of the Treasury, regarding Comments on Foreign Account Tax Compliance Act (FATCA) Provisions of the Hiring Incentives to Restore Employment (HIRE) Act, September 8, 2010
Letter to Stephen Schaeffer, Internal Revenue Service, regarding Comments on Proposed Costs Basis Reporting Regulations, August 27, 2010
Letter to Courier Desk, Internal Revenue Service, regarding Custodian Withholding Obligations With Respect to Distributions by Publicly Traded Partnerships - Need for Guidance, March 22, 2010
Letter to Stephen Schaeffer, Internal Revenue Service, regarding Reporting of Adjusted Basis in Securities Transactions - Notice 2009-17, April 20, 2009
Letter to U.S. Department of the Treasury and Internal Revenue Service, Commenting on CC:PA:LPD:PR (REG-140206-06); Proposed Regulation Section 1.1441-3, January 22, 2008
Letter to Frank Ng and Tina Byrd, IRS, from the AGC, DTC, SIA Dividend Division and the Clearing House Association, regarding Proposed Mutual Agreements Defining Eligibility for Treaty Benefits: Denmark, Germany, Finland, and Sweden, November 13, 2006
Letter to Commissioner Mark Everson, IRS, regarding Urgent Request for Delay in Implementation of User Free for Processing of Treaty Residency Certifications, September 28, 2006
Letter to Aziz Benbrahim, Tax Treaty Group Manager, International Tax Treaty Division, Internal Revenue Service, regarding: July 25, 2005 Meeting with the Association of Global Custodians, September 2, 2005
July 25, 2005 Meeting with the Association of Global Custodians, September 2, 2005
Letter to Curtis G. Wilson, Assistant Chief Counsel, Administrative Provisions and Judicial Practice, Internal Revenue Service and Harry J. Hicks III, Associate Chief Counsel, International, Internal Revenue Service, regarding: Form 8802 (Application for U.S. Residency Certification) - Term of Validity, May 27, 2005
Letter to Robert Green, Director, International, Internal Revenue Service, regarding: Form 8802 (Application for U.S. Residency Certification) - Term of Validity and Timing of Submission, May 27, 2005
Letter to Robert Green, Director, International, Internal Revenue Service, regarding: Request for Mutual Support, January 11, 2005
Letter to Robert Green, Director, International, Internal Revenue Service, regarding: U.S. Residency Certification--Forms 6166 and 8802, July 30, 2004
Letter to Robert Green, Director, International and Elvin Hedgpeth, Deputy Director, International, Office of Tax Treaty, Internal Revenue Service, regarding: Form 8802 and Related Procedures, April 13, 2004
Italy
Letter to Director of International Tax Policy and Legislation, Ministry of Finance, International Tax Policy and Legislation Directorate, regarding Association of Global Custodians - Request for Mutual Agreement Procedure under Article 26 of the Italy - Netherlands Income Tax Treaty, September 26, 2012
Letter to Michael Danilack, Internal Revenue Service, regarding Association of Global Custodians: Request for Competent Authority Assistance Under Article 25 of United States - Italy Income Tax Treaty, February 8, 2011
Letter to Italian Authorities regarding Unpaid Claims on Withheld Tax (in English and Italian), September 18, 2009
Letter to Dott Gianni Giammarino, Direttore Centrale Gestione Tributi, regarding: Italian Tax Repayment Issues, May 11, 2004
Japan
Letter to Keiji Aoyama, Deputy Commissioner (International Affairs), National Tax Agency, regarding: Follow-up on the Requirements to Comply with the New U.S./Japan Tax Treaty, February 22, 2005
Letter to Keiji Aoyama, Deputy Commissioner (International Affairs), National Tax Agency, regarding: Requirements to Comply with the New U.S./Japan Tax Treaty, September 15, 2004
Korea
CIV Industry Coalition Letter to Korean Ministry of Strategy and Finance on Impact of Korean Capital Gains Tax on Non-Korean CIVs, January 27, 2018
Letter to Korean Ministry of Strategy and Finance on Korea's Capital Gains Tax Changes for Foreigners, January 27, 2018
Letter to Marlies de Ruiter, OECD, regarding OECD Revised Discussion Draft, BEPS Action 6 - Preventing Treaty Abuse, June 16, 2015
Letter to Marlies de Ruiter, OECD, regarding OECD Discussion Draft, Follow-Up Work on BEPS Action 6 - Preventing Treaty Abuse, January 9, 2015
Letter to Mr. Dae-Young Kwon, Financial Services Commission, regarding US-Korea FATCA Agreement – Definition of “Account Holder” in the Context of Sub-Custody Accounts, March 25, 2014
Coalition Letter to Mr. Seunghee Han, Assistant Commissioner for International Tax Bureau, National Tax Service, and Mr. Byung-Sik Jung, Director of International Tax Division, Ministry of Strategy and Finance, regarding Administrative Obstacles Effectively Preventing CIVs from Receiving Tax Treaty Relief, October 22, 2012
Letter to Byung-Cheol Kim, Director, Corporation Tax Division, Ministry of Strategy and Finance, regarding Article 98-6 of the Corporate Income Tax Law and Draft Presidential Decree Article 138-7, Special Cases of Tax Withholding Procedures for Application of Reduced Tax Rates pursuant to Double Tax Treaties for Foreign Corporations, January 19, 2012
Letter to Jae-wan Bahk, Minister of Strategy and Finance and Hyun-dong Lee, Commissioner, National Tax Service, Republic of Korea, regarding The Status of Luxembourg SICAVs and SICAFs regarding Reduced Rates of Korean Withholding Tax under the Applicable Double Tax Treaty, June 24, 2011
Letter to Guy Heintz, Administration des Contributions Directes/Ministere des Finances, regarding The Status of Luxembourg SICAVs and SICAFs regarding Reduced Rates of Korean Withholding Tax under the Applicable Double Tax Treaty, June 7, 2011
Luxembourg
Letter to Jae-wan Bahk, Minister of Strategy and Finance and Hyun-dong Lee, Commissioner, National Tax Service, Republic of Korea, regarding The Status of Luxembourg SICAVs and SICAFs regarding Reduced Rates of Korean Withholding Tax under the Applicable Double Tax Treaty, June 24, 2011
Letter to Guy Heintz, Administration des Contributions Directes/Ministere des Finances, regarding The Status of Luxembourg SICAVs and SICAFs regarding Reduced Rates of Korean Withholding Tax under the Applicable Double Tax Treaty, June 7, 2011
Norway
Letter to Johanne Rian, Legal Adviser, The Royal Norwegian Ministry of Finance, regarding: Treaty Eligibility Under Norway-U.S. Income Tax Convention, February 28, 2009
Letter to Elisabet A. Landmark, Director, Norwegian Directorate of Taxes, regarding: Norwegian Dividend Withholding Tax Exemption, July 17, 2007
Organisation for Economic Co-operation and Development (“OECD”)
Letter to Marlies de Ruiter, OECD, regarding OECD Discussion Draft, The Treaty Residence of Pension Funds, April 1, 2016
Letter to Marlies de Ruiter, OECD, regarding OECD Discussion Draft – Preventing the Granting of Treaty Benefits in Inappropriate Circumstances, April 9, 2014
Letter to Achim Pross and Philip Kerfs, OECD, regarding Multilateral Automatic Exchange of Information and TRACE, July 26, 2013
Letter to Jeffrey Owens, Director, CTPA, Organisation for Economic Co-operation and Development, regarding OECD Discussion Draft - Clarification of the Meaning of "Beneficial Owner" in the OECD Model Tax Convention, July 13, 2011
Philippines
Poland
Portugal
Letter to Exmo. Senhor Prof. Sergio Vasques, Ministerio das Financas, regarding Tax Relief Arrangements on Portuguese Securities, March 4, 2011
Letter to Ministro das Financas, Professor Doutor Fernando Teixeira dos Santos, regarding: Administrative Tax Relief Arrangements on Portuguese Securities, July 17, 2007
Letter to Maria Manuela Dias Ferreira Leite, Ministra de Estado e das Financas, regarding: Portuguese Tax Relief Issues, March 5, 2004
Switzerland
U.S. Treasury
Unidroit Convention on Intermediated Securities
United Kingdom: Regulatory Issues
United States: Regulatory Issues
Letter to Jennifer Shasky Calvery, U.S. Department of the Treasury, regarding Association Comments regarding Customer Due Diligence Requirements for Financial Institutions; Notice of Proposed Rulemaking RIN 1506-AB25 ("NPRM"), October 14, 2014
Letter to Department of the Treasury, Office of the Comptroller of the Currency, Federal Deposit Insurance Corporation, Board of Governors of the Federal Reserve System and Securities and Exchange Commission regarding Comment Letter on the Notice of Proposed Rulemaking Implementing the Volcker Rule - Foreign Funds Designation and Definition of Trustee (Docket IDS -- OCC - 2011-14/RIN 1557-AD44; FRB Docket No. R-1432/RIN 7100 AD 82; FDIC RIN: 3064-AD85; SEC Release No. 34-65545/File No. S7-41-11/RIN: 3235-AL07), February 8, 2012
Letter to Don Donahue, The Depository Trust & Clearing Corporation ("DTCC"), regarding Universal Use of XBRL for Corporate Actions Messaging, November 10, 2010
Letter to Pierre Francotte, Euroclear and Don Donahue, The Depository Trust & Clearing Corporation ("DTCC"), regarding Depository Bank Loan Services - Interoperability Efforts, February 18, 2010
Letter to Janet Wynn, The Depository Trust & Clearing Corporation ("DTCC"), regarding Follow-up Actions to Further Promote Timely Call Announcements, February 18, 2010
Letter to Janet Wynn, The Depository Trust & Clearing Corporation ("DTCC"), regarding Industry-Wide Initiative to Review the Use and Risks of Protect Guarantees and Letters of Liability in Corporate Actions, January 12, 2010
Letter to Donald Donahue, The Depository Trust & Clearing Corporation ("DTCC"), regarding DTCC's Data Printouts, April 1, 2009
Letter to Robert J. McGrail, The Depository Trust & Clearing Corporation, regarding the Association's Views on Data Concerning Late Notices on Partial Calls and Recommended Action Steps, January 22, 2008
Letter to Robert J. McGrail, The Depository Trust & Clearing Corporation, regarding the September 2007 White Paper, Transforming Structured Securities Processing, November 15, 2007
