Double Up on Notifications Re:Taxation on Overseas Assets
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 government of another territory.
UK HMRC requires that the notification be made by 31st January in the calendar year following the first year in which the account held by the individual is a Reportable Account maintained by the reporting financial institution.
Additionally, UK HMRC requires certain financial advisors or service providers send a specific HMRC notification letter regarding potential taxes owed on overseas assets and income. This notification relates to clients/account holders with accounts as of September 30, 2016. The notification must be sent between September 30, 2016 and August 31, 2017.
To reduce costs and multiple client communications, it is worth considering combining these required notifications prior to the first notification deadline.