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 compli

The Mauritius Revenue Authority (MRA) announced that it has decided to extend the due date for the transmission of FATCA information to the MRA from July 31, 2017 to August 31, 2017 . Reporting to the MRA pursuant to the OECD Common Reporting Standard (CRS) does not commence until 2018. For assistance, please contact me via my contact page or at elizabeth@elizabethmcmorrowlaw.com .

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.

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)

Are you thinking that you have created an ingenious reporting avoidance scheme that no one can detect? Two words: disgruntled employee. As many violators of the U.S. Foreign Corrupt Practices Act (FCPA) have discovered, it is possible for a disgruntled employee or competitor to provide damaging information through a simple click. The OECD’s Common Reporting Standard’s (CRS) anti-avoidance rule prohibits schemes that intend to circumvent reporting under CRS. In order to ass

India’s Central Board of Direct Taxes (CBDT) issued an update regarding the US-India FATCA IGA. India and the USA entered into a Model 1 IGA for implementation of FATCA on 31st August, 2015. As part of the IGA implementation, India’s income tax rules included an alternate procedure for due diligence (Rule 114H(8)). If the financial institution determined that the self-certification was unacceptable and the account holder failed to cure the defect by 31 August 2016, then the f

All Foreign Financial Institutions (FFIs) that have entered into an FFI Agreement with the US Internal Revenue Service (IRS) must renew their FFI Agreements by July 31, 2017. The IRS anticipates that the FATCA portal will be ready for the FFI Agreement renewal process in May 2017. FATCA Portal Registration FFIs and other entities use the FATCA portal to obtain Global Intermediary Identification Numbers (GIINs). A GIIN is: the identification number that is assigned to a part

Singapore released its FATCA reporting nil paper form today. The Inland Revenue Authority of Singapore (IRAS) requires nil reporting under FATCA. Nil reporting can be accomplished through a paper form rather than through a complex electronic reporting process. US Reportable Accounts and Nil Reporting Under the IRAS FATCA Regulations, a Reporting FI is required to submit an annual return to IRAS setting out the required information in relation to (1) every US Reportable Accou

The Cayman Department for International Tax Cooperation (DITC) issued an industry advisory extending the dates for Common Reporting Standard (CRS) notification and reporting. The deadline for notification has been extended from April 30, 2017 to June 30, 2017. The deadline for reporting has been extended from May 31, 2017 to July 31, 2017. Reporting Financial Institutions (FIs) must submit their CRS data and show the status “Accepted” within the Submission History page of the

It may be startling for a headquarters executive or regional sales director to be asked to provide photocopies of every page in their passports, their date of birth and their social security number in order to start up a new foreign subsidiary. It may be equally surprising for an executive to discover that she may be required to provide sensitive personal information as part of the CRS and FATCA regimes – even in situations where she is not a signatory on the financial accou

In my practice, I represent clients in the financial industry (FATCA/CRS) and in the biotech industry (legal management of foreign subsidiaries). Given the rapid fire political changes, it is important for both industries to stay on top of U.S. regulations regarding Specially Designated Nationals (SDNs) and those listed on the Consolidated Sanctions List. Most organizations in the financial industry conduct Know Your Customer / Anti-money Laundering (KYC/AML) checks during t

The Cayman Islands, India, Mauritius and the majority of other jurisdictions participating in the Standard for Automatic Exchange of Financial Account Information in Tax Matters (The Common Reporting Standard (CRS)) are taking the “wider approach” to CRS compliance. What is the wider approach and how does it impact your CRS due diligence and reporting? Global Expansion Under FATCA, due diligence and reporting focused on one set of reportable persons: Specified U.S. Persons.