Sometimes I hear: “We’re not doing business in the U.S., so we are not at risk for not having a FATCA compliance program.” This wishful thinking is usually in the context of a business trying to determine how to allocate its limited budget. Ultimately, an attorney is an advisor, and it is the business people who take the advice, exercise their business judgment, and make a decision. However, it is important to have all the facts before reaching a decision. Enforcement Depends

The Bahamas Competent Authority announced the FATCA and Common Reporting Standard (CRS) portal will open for FATCA and CRS registration and reporting submissions on Thursday, October 1, 2026. Submissions for Y2026 reporting will be accepted May 1, 2027 through June 30, 2027. Also new on the Competent Authority home page is a link to a free one hour CRS 3.0 training on September 23, 2026 starting at 10 AM ET to be hosted by Regnology. Regnology is a financial industry service

The IRS announced the Public Key for FATCA filing will expire on September 24, 2026. For those financial institutions (FIs) who submit their FATCA reporting directly to the U.S. Internal Revenue Service (IRS), it is critical to determine if you have downloaded the IRS’ new public key and checked to see if your digital certificate is current. What Is IDES? Certain FIs transmit data directly to the IRS through the International Data Exchange Service (IDES). Depending on the amo

The U.S. Foreign Account Tax Compliance Act (FATCA) requires that Foreign Financial Institutions (FFIs) establish a compliance program consistent with the U.S. Internal Revenue Service’s (IRS) goal of detecting U.S. tax evaders who maintain certain financial accounts either directly in offshore accounts and investments or indirectly through ownership of foreign entities. The Organization of Economic Cooperation and Development (OECD) developed the Standard for Automatic Excha

A popular form of U.S. trust for non-U.S. Persons is the Foreign Grantor Trust (FGT). However, if the professional trustee does not take on FATCA tasks through the role of Sponsoring Entity, the trustee runs the risk of the FGT becoming a Non-Participating Foreign Financial Institution (NPFFI). What Is a Foreign Grantor Trust? A trust is established in a U.S. jurisdiction such as South Dakota or Nevada and a trustee is appointed. How could this trust be considered a non-U.S.

The U.S. Financial Crimes Enforcement Network (FinCEN) issued a final rule on August 11, 2026. The final rule removes the requirement for U.S. companies and U.S. persons to report beneficial ownership information (BOI) to FinCEN under the Corporate Transparency Act (CTA). FinCEN also announced it will delete previously reported information about individual U.S. persons from the BOI database. CTA Limited to Foreign Reporting Companies The new definition of “reporting company”

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. Then 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 was scheduled for January 1, 2028. The SIF has announced another delay to no earlier than January 1, 2029. M

On May 6, 2026, the United Kingdom HM Revenue & Customs (UK HMRC) added a “Deregistration” section to its International Exchange of Information Manual. The new section covers two topics: Deregistering as a User from the Reporting Service and Deregistering a Platform Operator. User Deregistration It is not possible to deregister as a user from the reporting service. Platform Operator Deregistration It is possible for a platform operator to be deregistered from the reporting se

The U.S. Internal Revenue Service (IRS) system “Filing Information Returns Electronically” (FIRE) is being replaced by “Information Returns Intake System” (IRIS) in 2027. A new type of Global Intermediary Identification Number (GIIN) will be used to solve the issue faced by certain foreign filers who may be unable to obtain a Social Security Number (SSN) or Individual Tax Identification Number (ITIN) for their authorized users. The lack of an SSN or ITIN would result in the a

On April 29, 2026, the United Kingdom HM Revenue & Customs (UK HMRC) published updates to its International Exchange of Information Manual. The updates include information related to partnerships, specified electronic money products (SEMPs), CRS reportable jurisdictions, and compliance penalties. Partnerships HMRC clarified that a UK Financial Institution (FI) includes an FI that is a Limited Partnership formed in the UK or a Limited Liability Partnership incorporated in the

On April 21, 2026, the Bahamas Competent Authority posted another CRS announcement with additional AEOI amendment information: Portal registration requirements and deadlines apply to both Reporting Financial Institutions (FIs) and Non Reporting FIs. Failure to register may result in a fine of up to $100,000 (Bahamian dollars are one to one with U.S. dollars). The Bahamas authority is to be notified within 90 days of an FI’s cessation for purposes of deregistration from the AE

The Bahamas has updated its International Tax Information Exchange page to indicate the FATCA / CRS portal will close on August 31, 2026 at 5PM. Previously, the site stated the portal would close on Tuesday, March 31, 2026 and reopen for Y2025 FATCA and CRS reporting in July 2026. For assistance, please contact me via my contact page or at elizabeth@elizabethmcmorrowlaw.com .

The Cayman Islands announced through a March 25, 2026 Industry Advisory that it is extending the deadline by which Cayman Reporting Crypto-Asset Service Providers (RCASPs) must register under the Crypto-Asset Reporting Framework (CARF). New Registration Deadline The deadline was April 30, 2026 and the new deadline is January 31, 2027. The extension is necessary to allow the Cayman Islands Department for International Tax Cooperation (DITC) time to build functionality in the e

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