The IRS issued the new monthly FFI List on November 1 for entities in approved status as of October 25. Some of you may have noticed the list was not in fact inclusive of entities through October 25. In fact, I am aware of an entity in approved status as of September 25 which was not included. The good news is that the IRS has now issued a second updated FFI List which claims to be inclusive as of October 27. For assistance, please contact me via my contact page or at...

On November 6 & 7, 2025, the United Kingdom HMRC announced updates to the International Exchange of Information Manual due to: CRS 2.0, updates to registration and reporting, updates to FATF, changes in AEOI schema. The following sections were updated: Investment Entity: Trusts Timetable: CRS Reporting Financial Institution: Electronic Money Institutions Custodial Institution: Introduction Investment Entity: Charities Investment Entity: Examples Investment Entity: Introductio

On October 31, 2025, the Singapore Inland Revenue Authority (IRAS) announced it has published updates to the Fourth edition of the Common Reporting Standard (CRS) e-Tax Guide, IRAS FAQs on CRS, and Second edition of the Common Reporting Standard (CRS) Compliance e-Tax Guide. The content of the IRAS announcements are below. " Fourth edition of the Common Reporting Standard (CRS) e-Tax Guide (PDF, 997KB) published with the following changes. Amended paragraphs 5.2.1 to 5.2.4 t

On October 23, 2025, the BVI International Tax Authority (ITA) issued a notice related to Common Reporting Standard (CRS) and the Crypto Asset Reporting Framework (CARF). BVI CRS 2.0 is effective starting January 1, 2026 with reporting on CRS 2.0 due May 2027. Additionally, BVI CARF exchange commitment commences in 2028. Below is the content of the BVI ITA notice. "The Virgin Islands intends to introduce CRS 2.0 with effect from 1st January, 2026. These means that by the end

The Bahamas Competent Authority announced the FATCA and Common Reporting Standard (CRS) portal will open for FATCA and CRS registration and reporting submissions on Wednesday, October 1, 2025 at 9 AM ET. The portal will close on Tuesday, March 31, 2026 at 5PM ET. Once the portal closes, Financial Institutions can contact the Bahamas Competent Authority at helpdesk@taxreporting.finance.gov.bs or information@taxreporting.finance.gov.bs . The portal will reopen for Y2025 FATCA

The IRS announced the Public Key for FATCA filing will expire on October 17, 2025. For those financial institutions (FIs) who submit...

On September 26, 2025, the United Kingdom’s HMRC updated its International Exchange of Information Manual to include a new section on Mandatory Registration. This new requirement is for Reporting Financial Institutions (FIs) and Trustee-Documented Trusts. Who & When? All Reporting FIs and Trustee-Documented Trusts must register by the later of December 31, 2025 or January 31 following the calendar year in which the entity first falls within the definition of Reporting FI or T

On August 5, 2025, the United Kingdom tax authority HMRC published an update to the International Exchange of Information Manual related to penalties. Circumstances When a Penalty Will Not Apply: Reasonable Care In an instance where a penalty would be owed for reporting inaccurate or incomplete information, no penalty will be due if the person took reasonable care. HMRC defines reasonable care as follows: “Where an inaccuracy in a document or an incomplete report has been mad

An incredibly frustrating aspect of business is providing a quality product or service to the customer and then not getting paid. You and...

On July 14, 2025, the Bahamas Competent Authority posted that effective immediately, Reporting Financial Institutions are required to report Undocumented Accounts. The document outlines special procedures that a Reporting FI must take when it is unable to obtain information from a Preexisting Individual Account Holder in order establish her tax residence. This link will take you to the document issued by the Bahamas: https://taxreporting.finance.gov.bs/wp-content/uploads/20

Timing is everything in life and timing counts in obtaining a GIIN for FATCA. Poor timing can impact opening a bank account, submitting...

The previously announced British Virgin Islands International Tax Authority (BVI ITA) Financial Account Reporting System (BVIFARS) payment system is finally live. The US$185.00 portal fee must be paid by June 1 annually through the BVIFARS portal. Who Does the Fee Apply to? The fee will be charged for each entity which is required under BVI law to register in BVIFARS. Entities register in BVIFARS to comply with BVI reporting under the Common Reporting Standard (CRS), Foreign

The Financial Crimes Enforcement Network (FinCEN) issued an interim final rule on Friday, March 21, 2025. The interim final rule removes the requirement for U.S. companies and U.S. persons to report beneficial ownership information (BOI) to FinCEN under the Corporate Transparency Act (CTA). The new definition of “reporting company” includes only those entities that are formed under the law of a foreign country and that have registered to do business in any U.S. state or trib

Many companies with operations outside of the U.S. have a U.S. limited liability company (LLC) or U.S. corporation as part of their...

You registered your Financial Institution in the U.S. Internal Revenue Service (IRS) FATCA portal. You received a Global Intermediary...

End of CTA / BOI The U.S. Government issued the following press release last night (Sunday, March 2, 2025): Treasury Department Announces Suspension of Enforcement of Corporate Transparency Act Against U.S. Citizens and Domestic Reporting Companies March 2, 2025 The Treasury Department is announcing today that, with respect to the Corporate Transparency Act, not only will it not enforce any penalties or fines associated with the beneficial ownership information reporting rule

On February 18, 2025, the U.S. District Court for the Eastern District of Texas eliminated the Smith nationwide injunction. In response, the Financial Crimes Enforcement Network (FinCEN) announced the Corporate Transparency Act (CTA) beneficial ownership information (BOI) reporting requirements are mandatory again. The new deadline is March 21, 2025. FinCEN also announced it intends to initiate a process in 2025 “to revise the BOI reporting rule to reduce burden for lower-ris