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  • Elizabeth A. McMorrow

FATCA & CRS: New Cayman Industry Advisory

The Cayman Islands AEOI Portal is currently online and open for notifications and reporting for all years. The deadline for both CRS and FATCA is July 31, 2019. The new Industry Advisory provides a number of updates regarding the portal user guide, error and status notifications, and frequently asked questions (FAQs).

The industry advisory also covers the below topics.

Sponsoring Entities & CRS Reporting

The industry advisory emphasizes that CRS does not recognize the Sponsoring / Sponsored Entity regime that is part of the U.S. – Cayman Islands Intergovernmental Agreement (FATCA IGA).

The FATCA IGA allows one entity (Sponsoring Entity) to fulfill a variety of obligations including FATCA IGA reporting on behalf of another entity (Sponsored Entity). The Sponsoring Entity registers in the U.S. Internal Revenue Service (IRS) FATCA portal and obtains a Global Intermediary Identification Number (GIIN) specific to its status as a Sponsoring Entity. The GIIN contains “SP.”

A Sponsored Entity that receives a GIIN through its Sponsoring Entity will also have a GIIN that contains “SP.”

If a Sponsoring Entity registers on the Cayman Islands AEOI portal for FATCA IGA purposes, it uses its GIIN with “SP” as the category code. However, the AEOI portal will recognize the “SP” and not permit this entity to complete the CRS Section B or Section C of the Cayman Islands Notification Form.

Instead, each of the Sponsored Entities must register on its own behalf for CRS in the AEOI portal and complete its own Cayman Islands Notification.

CRS Filing Declaration

The industry advisory reminds Cayman Islands Financial Institutions (FIs) that they are required to submit a CRS Filing Declaration even if the FI does not have any reportable accounts.

Through the CRS Filing Declaration, the FI:

  • Confirms it has submitted a Receiving Country Return for each Receiving Country where the FI has Reportable Accounts.

  • Confirms it has submitted a nil return for each Reportable Jurisdiction not specified as a Receiving Country in a Receiving Country Return.

  • Confirms the accuracy of the information submitted and that the FI has satisfied its reporting obligations under the CRS Regulations.

  • Acknowledges that there are sanctions for providing inaccurate information to the TIA and for violations of the FI’s reporting obligations.

CRS Participating Jurisdictions

No jurisdictions have been added to the Cayman Islands list of Participating Jurisdictions since the Cayman Islands February 1, 2018 Industry Advisory.

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