ELIZABETH A. McMORROW LAW LLC

Ph. +1.508.733.1807

elizabeth@elizabethmcmorrowlaw.com

Search

Elizabeth A. McMorrow

Jan 27

New Extension to Cayman CRS Compliance Form

The Department for International Tax Cooperation (DITC) announced the deadline for the first ever CRS Compliance Form is now September 15, 2021. This means that you will submit one form for your Y2019 data on September 15, 2021 and one form for your Y2020 data on the regularly scheduled deadline of September 15, 2021. Portal Adjustments The DITC extended the deadline to give itself more time to finalizeing the bulk upload feature. For those FIs who do not require the bulk upl

Elizabeth A. McMorrow

Dec 13, 2020

Cayman Portal Deadline & Penalties Update

The Cayman Islands Department for International Tax Cooperation (DITC) issued an Updates Bulletin dated December 10, 2020 with a number of important updates. Problems with the Portal & Flexible Deadline Given the technical problems users are experiencing with the DITC portal, the DITC announced that it will not be automatically issuing penalties to Financial Institutions (FIs) who are unable to complete their Common Reporting Standard (CRS) reporting by the December 16, 2020

Elizabeth A. McMorrow

Aug 26, 2020

FATCA: Mandatory Certification for GIIN Deregistration

The deregistration of an entity from the IRS FATCA portal may be necessary as a result of the sale, liquidation or other termination of an entity. However, simply clicking on “Agreement – Cancel” is not the end of the story. You may be required to submit a Certification of Preexisting Account (COPA) or Periodic Certification within six months of cancellation. IRS Certifications Certain entities may register in the IRS FATCA portal and, upon registration approval, receive a

Elizabeth A. McMorrow

Nov 20, 2019

FATCA & Privacy Year End Is Upon Us

Given that the departments usually handling FATCA, CRS and GDPR are swamped with a variety of other year-end tasks, this post may not be welcome . . . but you’ll thank me later! FATCA: Deregister Now & Avoid 2021 Reporting If you sell, liquidate or otherwise terminate a Reporting Foreign Financial Institution (FFI) by December 31, 2019 make sure you deregister it from the IRS FATCA portal. Certain jurisdictions require that a Reporting FFI submit a FATCA report even when the

Elizabeth A. McMorrow

Jun 4, 2019

FATCA: Add a Click to Deregistration

Your Foreign Financial Institution (FFI) has been sold or dissolved. You remember to cancel the FFI’s IRS FATCA portal registration. All done! After all, your FFI is a Reporting Model 1 FFI with no post -cancellation certification requirements. So, why is the IRS still indicating you are past due on certification? Portal Deregistration Deregistration from the IRS FATCA portal requires that the Responsible Officer (RO) or authorized person access the FFI account and click

FATCA: Deregister Now & Avoid 2020 Reporting

Elizabeth A. McMorrow

Dec 20, 2018

FATCA: Deregister Now & Avoid 2020 Reporting

If you sell, liquidate or otherwise terminate a Reporting Foreign Financial Institution (FFI) by December 31, 2018, now is the time to deregister it. Although you may be preparing for holiday vacation, you’ll be happy in 2020 that you won’t have to submit nil reports on these entities. Nil Jurisdictions Certain jurisdictions require that a Reporting FFI submit a FATCA report even when the FFI has no FATCA reportable accounts. This reporting is known as nil reporting. Juris

FATCA: July 22 Deregistration Cut-Off

Elizabeth A. McMorrow

Oct 29, 2018

FATCA: July 22 Deregistration Cut-Off

At recent conferences IRS staff announced a change in certification requirements that has not yet been added to the IRS FATCA FAQs. Regardless of the date of initial Global Intermediary Identification Number (GIIN) registration, an entity is now not required to complete FATCA certifications if it deregistered before July 22, 2018. July 22, 2018 Cut-Off Any entity that was deregistered from the IRS FATCA portal prior to July 22, 2018 is not required to submit a COPA or period

Elizabeth A. McMorrow

Nov 24, 2017

CRS & FATCA: Singapore Sub-Fund Deregistration & Service Provider Limitations

The Inland Revenue Authority of Singapore (IRAS) issued a reminder to financial institutions that an entity that is or becomes a Reporting Singapore-based Financial Institution (SGFI) at any time between January 1, 2017 and December 31, 2017 must apply for Singapore Common Reporting Standard (CRS) registration by March 31, 2018. IRAS also announced limitations on third-party reporting services and sub-fund FATCA deregistration requirements. Service Provider Limitations A Repo

Elizabeth A. McMorrow

Jul 25, 2017

FATCA & CRS: Don’t Forget to Deregister

If you sold, liquidated or otherwise terminated a Reporting Financial Institution (FI) prior to January 1 of this year, you may need to deregister that FI to avoid penalties for failure to update its registration or failure to report. The IRS and other tax authorities require FIs to register in a FATCA and/or CRS portal. If the registered FI was liquidated prior to January 1, it is likely that there will be no need to do CRS or FATCA reporting for the current financial year.