Insights
INSIGHTS
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CVM Expands Access to SCR Information for Securitization Companies and FIDC Managers
Oct 2026Read moreThe Brazilian Securities and Exchange Commission (“CVM”) issued, on October 2, 2026, CVM Resolution No. 247 (“CVM Resolution 247”), which amends CVM Resolution No. 60 and Regulatory Annex II to CVM Resolution No. 175. Its purpose is to improve how information is submitted to and consulted in the Central Bank of Brazil’s Credit Information System (“SCR”). The SCR is a database administered by the Central Bank that gathers info...
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CVM Clarifies that FIDC Performance Fees Cannot Be Tied to the Specialized Consultant’s Compensation
Sep 2026Read moreThe Securitization and Agribusiness Department (“SSE”) of the Brazilian Securities and Exchange Commission (“CVM”) published, on September 11, 2026, Circular Letter No. 3/2026/CVM/SSE (“Circular Letter”). It clarifies to administrators and managers of credit receivables investment funds (“FIDCs”) that the performance fee, or any portion of it, may not be allocated to specialized consultants engaged by the manager. The Circula...
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CMN Prohibits FIDC Investments in Legal Claims and Introduces New Transparency Regime for Existing Holdings
Sep 2026Read moreThe National Monetary Council (“CMN”) published, on September 24, 2026, Resolution No. 5,343 (“CMN Resolution 5,343”), which amended Resolution No. 2,907 of November 29, 2001 (“CMN Resolution 2,907”), governing the organization and operation of credit receivables investment funds (fundos de investimento em direitos creditórios) and funds of funds investing in credit receivables investment funds (collectively, “FIDCs”). As a r...
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Report of Bank and Financial Accounts Held Abroad: FBAR (Foreign Bank and Financial Accounts Report)
Aug 2026Read morePursuant to the Bank Secrecy Act of the United States of America (“U.S.”) and the regulations issued by the Financial Crimes Enforcement Network (“FinCEN”), a division of the U.S. Department of the Treasury responsible for combating money laundering, U.S. citizens (wherever they reside), other individuals considered U.S. tax residents (including green card holders), and entities organized under U.S. law (collectively, “U.S. Pe...
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Electronic Judicial Domicile
Mar 2026Read moreEstablished by the National Council of Justice (Conselho Nacional de Justica – CNJ), the Electronic Judicial Domicile (Domicilio Judicial Eletronico) centralizes, in a single environment, judicial service of process and procedural notifications, whose availability marks the beginning of the legal knowledge and the commencement of procedural deadlines, with a direct impact on the visibility and management of such deadlines. Co...
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Obligations of Limited Liability Companies with the IRS - Filing of Form 5472
Mar 2026Read moreU.S. limited liability companies ("LLCs") wholly owned by a single individual or legal entity that is not a resident of the United States of America ("U.S.") are classified, for these purposes, as foreign-owned U.S. disregarded entities and may be subject to the annual filing of Form 5472 with the Internal Revenue Service ("IRS"). This form is intended to report transactions carried out, in the prior fiscal year, between such...
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Deadline for Filing the Reference Form and the Electronic Compliance Declaration with the CVM Falls on March 31, 2026
Mar 2026Read moreThe deadline for securities portfolio managers and securities consultants — whether individuals or legal entities — holding an active registration with the Brazilian Securities and Exchange Commission ("CVM") to complete the annual update of the Reference Form ("FR") and to submit the Electronic Compliance Declaration ("DEC"), based on the positions as of December 31, 2025, falls on March 31, 2026, pursuant to CVM Resolutions...
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CVM Expands the Possibility of Assignment to FIDCs of Receivables by Companies Under Restructuring Proceedings
Mar 2026Read moreThe Brazilian Securities and Exchange Commission ("CVM") published, on March 6, 2026, Resolution No. 240 ("RCVM 240"), which amended Normative Annex II of Resolution No. 175, dated December 23, 2022 ("RCVM 175"), governing the specific rules applicable to receivables investment funds (fundos de investimento em direitos creditórios, "FIDC"). The rule concerns the regulatory treatment applicable to receivables assigned by compa...
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Amendments to the General Rules on ITCMD and ITBI in the Tax Reform
Jan 2026Read moreOn January 14, 2026, Complementary Law No. 227/2026 ("LC No. 227/2026") was published, introducing relevant amendments to the national tax legislation, particularly in the context of the Tax Reform. Set forth below are the most relevant aspects of the new legislation with respect to the following taxes: ITCMD: Tax on Transfer Causa Mortis and Donations, levied by the States and the Federal District ITBI: Tax on Onerous...
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LC No. 224/2025: Reduction of Tax Benefits, Increase in Deemed Profit Regime Margins
Jan 2026Read moreOn December 26, 2025, Complementary Law No. 224/2025 ("LC No. 224/2025") was published, introducing several relevant amendments to the tax legislation, in particular (i) the reduction of various tax benefits, (ii) the increase in deemed profit margins for the Assumed Profit (Lucro Presumido) regime; (iii) the increase in the Social Contribution on Net Income (CSLL) rate applicable to certain financial institutions; and (iv) th...
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Central Bank of Brazil Regulates Banking as a Service (BaaS)
Dec 2025Read moreThe Central Bank of Brazil ("Bacen") and the National Monetary Council ("CMN") published, on November 28, 2025, Joint Resolution No. 16 ("Joint Resolution No. 16"), establishing the regulatory framework for the provision of services under Banking as a Service ("BaaS") arrangements by financial institutions, payment institutions, and other institutions authorized to operate by Bacen. The new rule is the result of Public Consult...
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CVM Issues Guidance on FIDCs, FIAGROs, and FIIs
Nov 2025Read moreThe Securitization and Agribusiness Superintendency ("SSE") of the Brazilian Securities and Exchange Commission ("CVM") published, on November 17, 2025, Circular Letter No. 8/2025/CVM/SSE ("Circular Letter"), setting forth relevant clarifications on the application of provisions of Normative Annexes II, III, and VI to CVM Resolution No. 175, particularly with respect to the operation of Receivables Investment Funds (Fundos de...