The Foreign Account Tax Compliance Act (FATCA) aims to combat tax evasion by providing the IRS with information about U.S. accounts held at foreign financial institutions (FFIs) and imposing a 30% withholding tax on payments to FFIs that fail to register with the IRS by April 25, 2014.  For hedge fund managers, FATCA creates a broad new registration, compliance and reporting regime.  In a guest article, Rod White, Regional CEO of Equinoxe Alternative Investment Services for Bermuda and U.S. operations, identifies six of the primary challenges that hedge fund managers and their service providers face in complying with that new regime.  See also “A Checklist for Updating Hedge Fund and Service Provider Documents for FATCA Compliance,” Hedge Fund Law Report, Vol. 7, No. 7 (Feb. 21, 2014).