Recently released Cayman Islands Common Reporting Standard (CRS) Regulations added significant criminal enforcement sections which include the imposition of administrative and criminal fines on individual account holders providing self-certificates and individuals connected to an entity violating the Cayman CRS Regulations and Tax Information Authority (TIA) Law. The changes were made through the Cayman Islands issuing the Tax Information Authority (International Tax Complian

The Cayman Islands issued The Tax Information Authority (International Tax Compliance) (Common Reporting Standard) (Amendment) Regulations, 2016. These regulations amend the Tax Information Authority (International Tax Compliance) (Common Reporting Standard) Regulations, 2015. Non-Reporting Financial Institutions (FIs) are now required to register with the Cayman Islands TIA by April 30, 2017 (or by April 30 of the year after the entity becomes an FI). Change in Approach

To provide a bridge between the start of FATCA and the time necessary for jurisdictions to enter into Intergovernmental Agreements (IGAs) and implement local legislation, the IRS created a limited conditional status. Pursuant to this status, certain branches and Foreign Financial Institutions (FFIs) were able to register with the IRS as a “Limited Branch” or “Limited FFI.” As of January 1, 2017, the “Limited” status terminates. If a Limited Branch or Limited FFI is still un

Have you heard the story about the ex-pat driving home along a European country road who hit a telephone pole? How about the part of the story where the power was knocked out to the adjacent farm disrupting the sleep of the farmer’s cows and resulting in the farmer threatening to sue the ex-pat for the cow’s sleep deprivation? And then there was the ex-pat assigned to a Central American country who discovered (just before fleeing out the bedroom window) that his paramour was

In April 2016, the IRS released a new Form W-8BEN-E. Ordinarily, the old 2014 Form W-8BEN-E would be permitted to be used for six months...

Pursuant to local CRS and FATCA implementation, certain jurisdictions such as the United Kingdom require that Reporting Financial Institutions notify each individual Reportable Person or individual Specified U.S. person about government to government data sharing. Specifically, the client must be notified that information relating to that person which is required to be reported under FATCA and CRS will be reported to the local tax authority and may be transferred to the gove

The IRS requires that some sponsoring entities register their sponsored entities for their own Global Intermediary Identification Numbers...

In April 2016, the IRS released a new Form W-8BEN-E. The old 2014 Form W-8BEN-E is permitted to be used for six months subsequent to the release of the new form. The mandatory date to use the 2016 form is creeping up on us as November 1, 2016 approaches. For a Form W-8BEN-E, the validity period is generally the period starting on the date the form is signed and ending on the last day of the third succeeding calendar year absent a change in circumstances. For example, a Fo

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)). This rule required financial institutions to obtain self-certifications from account holders who had opened new accounts as of 1 July 2014. The due diligence process also included a requirement that the financial institution determine the reasonableness of t