EFTA01115824Set 9
2014-02-26181p90,937w
financial institutions in a partner jurisdiction.n46 Under the first alternative, known as Model 1
IGA, the foreign government agrees to collect the specified FATCA disclosure information,
including U.S. accountholder names ... IFATCA
Partner] to Improve International Tax Compliance and to Implement FATCA," Model IA IGA Reciprocal,
Preexisting TIEA or DTC agreement (Nov. 4, 2013), http://www.treasury.gov/resource-center/tax-
policy/treaties/Documents/FATCA-Reciprocal•Model-IA-Agreement-Preexisting-TIEA-or-DTC-11-443.pdf. The
United ... States also offers a nonreciprocal version of the agreement, referred to as Model 1B IGA. For the text of the
EFTA01115845
18
alternative, known as Model 2 IGA, the foreign
https://www.justice.gov/epstein/files/DataSet%209/EFTA01115824.pdf
EFTA01115643Set 9
2014-02-26181p90,956w
financial institutions in a partner jurisdiction.n46 Under the first alternative, known as Model 1
IGA, the foreign government agrees to collect the specified FATCA disclosure information,
including U.S. accountholder names ... IFATCA
Partner] to Improve International Tax Compliance and to Implement FATCA," Model IA IGA Reciprocal,
Preexisting TIEA or DTC agreement (Nov. 4, 2013), http://www.treasury.gov/resource-center/tax-
policy/treaties/Documents/FATCA-Reciprocal-Model-IA-Agreement-Preexisting-TIEA-or-DTC-11-443.pdf. The
United States ... also offers a nonreciprocal version of the agreement, referred to as Model 1B IGA. For the text of the
EFTA01115664
18
alternative, known as Model 2 IGA, the foreign government
https://www.justice.gov/epstein/files/DataSet%209/EFTA01115643.pdf
EFTA00179613Set 9
2013-09-20184p62,857w
notes, tion; Overriding Need; Claims
thru handwritten attorney (Villaf subjec t to inv est iga tive Inv oca
ct at Issue;
grand jury c Prosecutor, Attorney Condu
P-001007 target ... Invocation; Overriding Need;
thru attorney (Villafaila) notes and sub jec t to inv est iga tive Issue;
of FedEx subpoena response ele
ctronic file Prosecutor, Attorney Conduct ... tain ing records received in
est iga tive Lit iga tion ; Im proper Invocation; Overridin
P401 subject to inv urt Authorized
thru response to grand jury subpoena privilege Need; Factual
https://www.justice.gov/epstein/files/DataSet%209/EFTA00179613.pdf
EFTA00673127Set 9
2014-12-103p912w
British Virgin Islands have each entered into a "Model 1
Intergovernmental Agreement" ("IGA") with the United States which modifies the applicable FATCA
compliance rules for investment funds organized in such ... funds in certain other jurisdictions). Thus, under FATCA as modified by the IGAs,
offshore funds based in Cayman or BVI would become subject to US 30 percent withholding on
January ... vehicles that are classified as "Non-Reporting Financial Institutions" under the terms of
such IGAs are exempt from these IRS registration requirements, but the typical offshore fund generally
would
https://www.justice.gov/epstein/files/DataSet%209/EFTA00673127.pdf
EFTA01353905Set 10
2018-12-311p811w
United States have entered into a Model 1 intergovernmental agreement (the "U.S. IGA')
relating to FATCA and the United Kingdom has brought into law regulations to implement the provisions ... IGA
(such regulations and any future implementing laws, rules or regulations, the 'UK FATCA Legislation"). The Fund will
be required to comply with the UK FATCA Legislation, which will require ... related entity to comply with any requirements relating
to FATCA, including the U.S. IGA, the UK FATCA Legislation, and any other non-U.S. law enacted in connection with
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01353905.pdf
EFTA01389837Set 10
2018-12-311p808w
United States have entered into a Model 1 intergovernmental agreement (the "U.S. IGA')
relating to FATCA and the United Kingdom has brought into law regulations to implement the provisions ... IGA
(such regulations and any future implementing laws, rules or regulations, the 'UK FATCA Legislation"). The Fund will
be required to comply with the UK FATCA Legislation, which will require ... related entity to comply with any requirements relating
to FATCA, including the U.S. IGA, the UK FATCA Legislation, and any other non-U.S. law enacted in connection with
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01389837.pdf
EFTA01393684Set 10
2018-12-311p808w
United States have entered into a Model 1 intergovernmental agreement (the "U.S. IGA')
relating to FATCA and the United Kingdom has brought into law regulations to implement the provisions ... IGA
(such regulations and any future implementing laws, rules or regulations, the 'UK FATCA Legislation"). The Fund will
be required to comply with the UK FATCA Legislation, which will require ... related entity to comply with any requirements relating
to FATCA, including the U.S. IGA, the UK FATCA Legislation, and any other non-U.S. law enacted in connection with
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01393684.pdf
EFTA01355475Set 10
2018-12-311p809w
United States have entered into a Model 1 intergovernmental agreement (the "U.S. IGA')
relating to FATCA and the United Kingdom has brought into law regulations to implement the provisions ... IGA
(such regulations and any future implementing laws, rules or regulations, the 'UK FATCA Legislation"). The Fund will
be required to comply with the UK FATCA Legislation, which will require ... related entity to comply with any requirements relating
to FATCA including the U.S. IGA the UK FATCA Legislation, and any other non-U.S. law enacted in connection with
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01355475.pdf
EFTA01394656Set 10
2018-12-311p809w
United States have entered into a Model 1 intergovernmental agreement (the "U.S. IGA')
relating to FATCA and the United Kingdom has brought into law regulations to implement the provisions ... IGA
(such regulations and any future implementing laws, rules or regulations, the 'UK FATCA Legislation"). The Fund will
be required to comply with the UK FATCA Legislation, which will require ... related entity to comply with any requirements relating
to FATCA, including the U.S. IGA, the UK FATCA Legislation, and any other non-U.S. law enacted in connection with
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01394656.pdf