Once again, the Cayman Islands has extended the deadline for FATCA and Common Reporting Standard (CRS) reporting from May 31 to July 31.

Cayman Islands Portal Open

The Cayman Islands Department for International Tax Cooperation (TIA) also announced that its Automatic Exchange of Information (AEOI) portal is open for FATCA and CRS reporting submissions. Now is the time to submit any 2014 - 2017 reporting that you failed to submit previously while the portal is not bombarded with 2018 reporting.

Nil Filing

If you have CRS reporting obligations but nothing to report: do not forget to file a nil report.

Recalcitrants

Pursuant to the U.S.-Cayman Islands Model 1 Intergovernmental Agreement (IGA), a Cayman Islands Financial Institution (FI) is required to obtain a tax identification number (TIN) for each Specified U.S. Person.

If an FI has not been able to obtain a TIN or the TIN is considered unreliable, the FI should leave the TIN reporting field blank. The IRS will generate an error notification requiring the TIN to be provided. The TIA will consider the Account Holder, Payee, or U.S. organization owner that is a Specified U.S. Person as recalcitrant and may take regulatory action.

Sponsored Entities

Unlike FATCA, CRS does not recognize the Sponsored Entity and Sponsoring Entity concepts. Accordingly, the Cayman Islands requires the Sponsored FI to register for CRS purposes with a new Notification Form.

For assistance, please contact me via my contact page or at elizabeth@elizabethmcmorrowlaw.com.