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International Tax: FATCA & CRS


The U.S. Foreign Account Tax Compliance Act (FATCA) seeks to detect U.S. tax evaders who maintain financial accounts either directly in offshore accounts and investments or indirectly through ownership of foreign entities. Similarly, the Common Reporting Standard (CRS) seeks to improve tax compliance through the automatic exchange of information between participating jurisdictions.

The laws impact financial institutions, companies outside the financial industry, and individuals. FATCA and CRS compliance issues impact organizations and individuals in the following ways:

  • Financial institutions must create internal compliance programs and undertake annual reporting to their national tax authority

  • Companies outside the financial industry must provide financial institutions with complex IRS withholding forms and CRS self-certifications for existing and new accounts

  • Individuals must also provide IRS withholding forms and CRS self-certifications

  • Individual account holders must determine whether they are considered a "U.S. Person" and in which jurisdictions they are considered residents

I work in tandem with CFOs, tax directors, and in-house counsel to develop, customize, implement, and evaluate internal compliance programs and procedures to ensure compliance with international tax transparency regimes.  My representation includes the following:

  • Advise fintechs, banks, hedge funds, asset managers, trusts and fund administrators regarding FATCA, Intergovernmental Agreements (IGAs), and CRS.

  • Evaluate financial institutions’ legal entity structures (including deal structures) for FATCA and CRS classifications

  • Register client entities with the IRS (obtain Global Intermediary Identification Numbers ("GIINs")) and in IGA and CRS multi-jurisdictional portals

  • Complete IRS forms and CRS self-certifications

  • Draft Sponsoring Entity Agreements

  • Counsel and prepare clients for IRS, IGA and CRS multi-jurisdictional reporting

  • Communicate with the IRS and foreign tax authorities to resolve client issues

  • Develop corporate policies and procedures and compliance training

For more information, you may contact me via my site contact page or directly via e-mail:

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