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FATCA & CRS: Cayman Portal Closing September 13, 2017

The Cayman Islands issued a reminder to Financial Institutions that the deadline for the submission of US FATCA and CRS reports and CRS Filing Declarations is today August 31, 2017. Although the deadline for registration was July 31, 2017 and the deadline for registration/notification is August 31, 2017, the Cayman Islands is keeping its portal open until September 13, 2017. Specifically, the portal will be open until 4 P.M. on September 13, 2017: New York 5 P.M. / London 10 P.M. / Tokyo 6 A.M. September 14. The AEOI Portal will accept late registrations, variations, reporting and filing declarations prior to the closure of the Portal for the preparation of data for submission. For assista

FATCA & CRS: Perfect Reporting Process But Still Non-Compliant

Reporting is almost over and you can take a breath. You followed FATCA, IGA, CDOT and CRS requirements in your reporting and due diligence. But did you document these processes? If not, you may still be subject to penalties. FATCA, CDOT and CRS each seeks to create transparency in taxation across jurisdictions. The local tax authority collects certain information through the reporting process and shares that information with relevant tax authorities. It is incumbent on the reporting financial institution to create internal processes that allows it to collect and report the required FATCA/CDOT/CRS account holder data. You may have created effective, streamlined processes that leave you c

CRS: BVI Extends Reporting Deadline to September 1

The British Virgin Islands tax authority announced that it has extended the deadline for UK FATCA/CDOT and Common Reporting Standard (CRS) reporting to September 1, 2017. This extension applies to UK FATCA/CDOT and CRS. The extension does not apply to FATCA. For assistance, please contact me via my contact page or at elizabeth@elizabethmcmorrowlaw.com. #BVI #BritishVirginIslands #CRS

FATCA & CRS: Cayman Allows Post Deadline Registration / Notification / Variation

The Cayman Islands announced yesterday that its AEOI portal will continue to accept Financial Institution (FI) registrations and variations to existing FI registrations until August 31, 2017. The Department for International Tax Cooperation (DITC) warned that it is possible that fines may be levied against those that did not meet the July 31, 2017 deadline. Additional fines may be levied if an FI fails to register prior to August 31, 2017. Please note that it is necessary to register even if the FI has no reporting obligations. Additionally, even if the FI previously registered for FATCA and CDOT, it must update its registration to comply with Cayman Islands CRS requirements. The Cayman Is

FATCA: The IRS Extends FFI Agreement Registration Renewal Deadline

A Foreign Financial Institution (FFI) that seeks to renew its FFI agreement must do so prior to October 24, 2017. The deadline had previously been July 31, 2017. The effective date of an FFI Agreement is the date on which the IRS issues a Global Intermediary Identification Number (GIIN) to the FFI. FFIs that have already entered into an FFI Agreement must renew their FFI Agreements in the FATCA portal. If the FFI completes its renewal by October 24, 2017 and it is in compliance with the new FFI Agreement since January 1, 2017, then the FFI’s renewal will be “backdated” to January 1, 2017. However, an FFI that does not renew its FFI agreement by October 24, 2017, will be treated as having t

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