On March 12, 2026, the Bahamas Competent Authority issued the updated Common Reporting Standard (CRS) activation list for Y2025 reporting. The list includes 73 jurisdictions with Rwanda and Uganda being added. The FATCA and CRS portal is currently open for FATCA and CRS registration and pre-Y2025 reporting submissions. The portal will close on Tuesday, March 31, 2026 at 5PM ET. Once the portal closes, Financial Institutions can contact the Bahamas Competent Authority at...

On March 10, 2026, the Guernsey Revenue Service published a bulletin (2026/02) providing the FATCA and Common Reporting Standard (CRS) reporting deadlines and outlining the penalties associated with late reporting. Deadlines FATCA and CRS reporting for Y2025 data is due on or before Tuesday, June 30, 2026. There is a delay of potentially weeks between an entity registering in the U.S. Internal Revenue Service (IRS) FATCA portal and the entity appearing on the IRS FFI List . T

I enjoyed chatting with Mishkin Santa of The Wolf Group on his podcast The Essential Tax Podcast. We covered a range of subjects related to FATCA, CRS & CARF. Check out the episode on any of the following platforms: Apple Podcasts Spotify Podcasts Amazon Podcasts iHeart Radio Podcasts YouTube Video For assistance, please contact me via my contact page  or at elizabeth@elizabethmcmorrowlaw.com .

On February 9, 2026, the Mauritius Revenue Authority (MRA) posted three communiques related to the Common Reporting Standard (CRS). Day 1 Self-Certifications The MRA announced stronger requirements related to the collection of customer / investor self-certifications. Self-certifications are required to be collected from all new individual and entity account holders as well as from controlling persons of Passive Non-Financial Entities (NFE). Previously, a Financial Institution

Switzerland Delays Model 1 IGA On June 27, 2024, the U.S. and Switzerland signed a new FATCA agreement changing Switzerland from a Model 2 Intergovernmental Agreement (IGA) jurisdiction to Model 1 IGA jurisdiction starting in 2027. However, on January 26, 2026, Switzerland’s State Secretariat for International Finance SIF announced that the earliest entry into force of the U.S.-Switzerland Model 1 IGA is scheduled for January 1, 2028. Model 2 IGA The U.S.-Switzerland Model 2

On January 23, 2026, the Guernsey Revenue Service published a bulletin (2026/01) with a revised list of 111 CRS Reportable Jurisdictions for the Y2025 reporting period. Guernsey removed Tunisia from its list of CRS Reportable Jurisdictions and added Cameroon and Qatar. The deadline for submitting Y2025 CRS reporting in the Guernsey IGOR portal is June 30, 2026. For Y2026 Reportable Jurisdictions (deadline June 30, 2027), Guernsey has provisionally included: Papua New Guinea a

The Cayman Islands announced an extension to the new requirement that the Principal Point of Contact (PPoC) be a resident in the Cayman Islands. FI Registration Deadline For entities created in 2025, the Cayman Islands requires that reporting and non-reporting Financial Institutions (FIs) submit a “Notification” by registering in the Cayman Islands DITC Portal by April 30, 2026. Registration is required under both the U.S.-Cayman Islands FATCA IGA and the Common Reporting Sta

On January 8, 2026, the United Kingdom HM Revenue & Customs (UK HMRC) updated the list of reportable jurisdictions in its International Exchange of Information Manual. The changes since the 2025 reporting year are that Cameroon and Tunisia have been added to the list. Reportable Jurisdictions The following is the complete HMRC list of Reportable Jurisdictions under the Common Reporting Standard (CRS) for the 2026 reporting year with respect to Y2025 reportable accounts: Alban

The Bahamas Competent Authority (CA) issued a Notice of Enforcement of Penalties for Late Filing of Information Returns on January 7, 2026. The CA noted that there has been a continuing problem with late filings. Although the CA may have been flexible in previous years, it intends to impose penalties going forward. Late Filing Penalty Notice “Where a Financial Institutions receives a notice indicating that a filing is late and that a penalty is payable, the entity is required

On December 31, 2025, the Guernsey Revenue Service published a bulletin announcing changes to its Common Reporting Standard (CRS) regulations to include CRS 2.0. These changes have effect from January 1, 2026. The Bulletin indicates Guernsey may impose a penalty of up to £10,000 on an individual or Entity which does not provide a valid self-certification with respect to their role as an Account Holder or Controlling Person. Bulletin 2025/2 outlines certain changes in reportin

The Cayman Islands published updated regulations related to the Common Reporting Standard (CRS). Certain changes are effective as of January 1, 2026 while others will come into effect in subsequent years. Primary Point of Contact (PPoC) Currently, as part of the online Cayman Islands Notification process, it is necessary to appoint an Authorizing Person and Principal Point of Contact (PPoC) for each Financial Institution (FI). The PPoC can be an individual who is resident out

On December 4, 2025, the United Kingdom HMRC published an update to the International Exchange of Information Manual “Reportable Information: Joint Accounts”. Commencing with reporting on Y2026 data to be submitted in 2027, Financial Institutions (FIs) must identify if Reportable Accounts are joint accounts. If yes, then the number of joint account holders must be reported. Additionally, if a new joint account holder is added to a pre-existing account, the FI is required to u

The IRS issued the new monthly FFI List on November 1 for entities in approved status as of October 25. Some of you may have noticed the list was not in fact inclusive of entities through October 25. In fact, I am aware of an entity in approved status as of September 25 which was not included. The good news is that the IRS has now issued a second updated FFI List which claims to be inclusive as of October 27. For assistance, please contact me via my contact page   or at...

On November 6 & 7, 2025, the United Kingdom HMRC announced updates to the International Exchange of Information Manual due to: CRS 2.0, updates to registration and reporting, updates to FATF, changes in AEOI schema. The following sections were updated: Investment Entity: Trusts Timetable: CRS Reporting Financial Institution: Electronic Money Institutions Custodial Institution: Introduction Investment Entity: Charities Investment Entity: Examples Investment Entity: Introductio