FATCA 2014. CRS 2016. Your organization has studied the rules for these regimes and employees know exactly what needs to be done. You’re thrilled that everyone has been doing their jobs well over the past years. But did you document these processes and update them? If not, you may still be subject to penalties. FATCA v CRS FATCA and CRS seek to create transparency in taxation across jurisdictions. The local tax authority collects certain information from Financial Institution

The Cayman Islands previously extended the deadline for Y2019 FATCA reporting to November 16, 2020. Cayman Islands Department for International Tax Cooperation (DITC) has now also extended the deadline for Y2019 CRS reporting to November 16, 2020 . Global Forum The Global Forum on Transparency and Exchange of Information for Tax Purposes (Global Forum) recognized tax authorities and Financial Institutions (FIs) will have difficulty meeting their respective 2020 CRS deadlines

The Cayman Islands announced the deadline for Y2019 FATCA reporting has been extended to November 16, 2020. However, the deadline for CRS remains September 18, 2020. IRS Government to Government Extension Earlier this week, the IRS announced that it was granting an extension for the government to government exchange of Model 1 IGA FATCA Y2019 data from September 30, 2020 to December 31, 2020. In light of this extension, the Cayman Islands Department for International Tax Coop

The Cayman Islands announced today that the deadline for Y2019 FATCA/CRS reporting has been extended to September 18, 2020 and the annual FATCA/CRS reporting deadline for future years has been changed to July 31. The Cayman Islands Department for International Tax Cooperation (DITC) expects to launch its new portal on June 1, 2020. Until then, it will not be possible to register entities (notification), undertake reporting, amend returns or update any current data. While th

Previously, the Cayman Islands stated that its FATCA/CRS AEOI portal was offline for maintenance. [See my August 31, 2019 blog post: FATCA & CRS: Cayman Portal Closed ]. However, the Cayman Islands Department for International Tax Cooperation (DITC) announced this week that it is developing a new AEOI Portal for notification and reporting purposes. The new portal is scheduled to launch in two phases over the first and second quarters of 2020. The portal will include additi

The Cayman Islands Department for International Tax Cooperation (DITC) announced Friday that its AEOI portal is offline to facilitate the transmission of CRS and FATCA returns to partner jurisdictions. Users will be able to login and check on previously submitted returns to address errors and submit any outstanding returns when the portal is reopened on October 7, 2019 at 2:00 PM (EST). The DITC notice indicates that the DITC updated the CRS Reportable Jurisdictions list. H

The Cayman Islands AEOI Portal is currently online and open for notifications and reporting for all years. The deadline for both CRS and FATCA is July 31, 2019. The new Industry Advisory provides a number of updates regarding the portal user guide, error and status notifications, and frequently asked questions (FAQs). The industry advisory also covers the below topics. Sponsoring Entities & CRS Reporting The industry advisory emphasizes that CRS does not recognize the Sp

Once again, the Cayman Islands has extended the deadline for FATCA and Common Reporting Standard (CRS) reporting from May 31 to July 31. Cayman Islands Portal Open The Cayman Islands Department for International Tax Cooperation (TIA) also announced that its Automatic Exchange of Information (AEOI) portal is open for FATCA and CRS reporting submissions. Now is the time to submit any 2014 - 2017 reporting that you failed to submit previously while the portal is not bombarded

The Bahamas issued revised CRS Guidance Notes on August 3, 2018. Included in the revisions is a change in the definition of Controlling Person. The Bahamas will now use a 10% threshold for CRS reporting commencing in 2019. Controlling Person Defined The Bahamas CRS Guidance provides the following definition for Controlling Person: Any natural person that holds directly or indirectly more than twenty-five percent (25%) of the shares or voting rights of an Entity as a benef

Certain Cayman Islands entities must provide beneficial ownership information to their Cayman Islands corporate service providers (CSPs) by June 29, 2018. This requirement should not be confused with the obligation to report Controlling Persons under FATCA Intergovernmental Agreements (IGAs) and CRS. The Cayman Islands created a centralized beneficial ownership register in 2017 that provides United Kingdom (UK) law enforcement and tax authorities with beneficial ownership in

The Cayman Islands changed its deadline for CRS and FATCA reporting: Original deadline May 31 Portal closed June 1 - June 14 Portal reopens June 15 New deadline July 31 Portal remains open until August 31 Please note that submissions made after July 31 will be noted and may be subject to compliance reviews by the Cayman Islands tax authority. For assistance, please contact me via my contact page or at elizabeth@elizabethmcmorrowlaw.com .

The Cayman Islands announced in March that it updated its CRS self-certifications to require that Passive Non-Financial Entities (NFEs) disclose individuals with direct or indirect ownership or control of 10% or more of the shares or voting rights of the Passive NFE. Previously, the threshold was 25%. Why the significant change? Quick Review: Controlling Person Controlling Persons are the natural persons who exercise control over the Passive NFE. This includes the natural

CRS placed a tremendous burden on financial institutions (FIs) during the 2017 reporting season. This burden will only increase during the 2018 reporting season. FIs should have already taken steps to ensure due diligence is underway for those jurisdictions with a January 1, 2017 due diligence requirement. Now is also the time to ensure that employees / third party service providers at the back end of the the actual reporting process are made aware of the increased reporti

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 1

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 th

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

The Cayman Islands announced that the reporting deadline for FATCA and CRS has been extended to August 31, 2017. This will be the final extension. The AEOI portal will close on August 31, 2017 at 4PM local time (3PM New York / 10PM London). The deadline for registration remains July 31, 2017. The Department for International Tax Cooperation (DITC) also issued a reminder that failure to register or report by the stated deadlines may result in a fine of KYD 50,000 (USD 61,000)

The Cayman Islands announced yesterday that it extended the deadline for Financial Institutions (FIs) to register in the Cayman Islands AEOI portal. Previously, the deadline was June 30, 2017. The deadline is now July 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 Cay

The Cayman tax authority announced on Friday that the Cayman AEOI portal is now open for FATCA and CRS entity registrations. For assistance, please contact me via my contact page or at elizabeth@elizabethmcmorrowlaw.com .

The Cayman Islands tax authority (TIA) issued an update for FATCA/CRS registration/notification and reporting. For assistance, please contact me via my contact page or at elizabeth@elizabethmcmorrowlaw.com .