Belgium and Australia have become the most recent countries to sign an Intergovernmental Agreement ("IGA") under FATCA with the United States. Both agreements are Model 1A form IGAs under which financial institutions in Australia or Belgium, as the case may be, will provide information about U.S. Reportable Accounts to its local tax authority, which will automatically forward such information to the U.S. IRS. In return, the United States promises to forward information currently reported under Chapter 3 of the Internal Revenue Code with respect to accounts held by Belgium or Australian

CBS Corp. recently announced that the IRS will permit CBS Outdoor Americas Inc. ("Outdoor") to convert to a real estate investment trust ("REIT"), which will receive more favorable tax treatment. Earlier this month, Outdoor completed an IPO, distributing 19% of its stock, and CBS plans to distribute its remaining Outdoor stock to CBS shareholders in a tax-free split-off later this year. Nugent Comment: A company generally can qualify as a REIT, which normally is taxed only at the shareholder level, if its business is based primarily on real estate holdings and it distributes at least 90% of

The CFTC announced that the United States District Court for the Northern District of Illinois issued a consent Order against a CFTC-registered floor trader and floor broker, settling charges that he exceeded speculative position limits in live and feeder cattle futures contracts. The Order found that the floor trader and broker held an aggregate live cattle futures net long position that totaled 620 contracts, exceeding the speculative position limits by 70 contracts, as well as aggregate futures equivalent net short positions in feeder futures contracts that exceeded the speculative position

The CFTC Division of Swap Dealer and Intermediary Oversight ("DSIO") issued no-action relief to a commodity pool operator ("CPO") regarding the Annual Report filing and certification requirements in CFTC Rules 4.22(c) and (d) ("Reporting to Pool Participants"). Additionally, the DSIO granted exemptive relief from CFTC Rule 4.22(d)(1) on the condition that the CPO file an uncertified Annual Report for the 2013 fiscal year, in full compliance with CFTC Rule 4.22(c), by May 31, 2014. See: CFTC Letter 14-61.

The SEC issued an Order granting a waiver to the Royal Bank of Scotland Group, Plc ("RBS") from being considered an ineligible issuer, pursuant to the definition of "ineligible issuer" in Securities Act Rule 405. RBS submitted a letter on March 27, 2014 that constituted an application for the waiver, due to the entry on January 14, 2014, of a judgment against RBS Securities Japan Limited, which found RBS Japan guilty of felony wire fraud. Paragraph 2 of the definition of "ineligible issuer" in Rule 405 states that an issuer shall not be an ineligible issuer if the SEC determines, upon showing