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  • Elizabeth A. McMorrow

FATCA/CRS News from Cayman Islands

The Cayman Islands Department for International Tax Cooperation (DITC) recently issued a news update regarding FATCA and Common Reporting Standard (CRS).


FATCA/CRS Portal Is Open

The DITC Portal is open for Y2022 FATCA and CRS XML uploads. The deadlines are as follows:


TINs & DoBs

The DITC reminded Financial Institutions (FIs) they are required to make a reasonable effort to obtain tax identification numbers (TINs) and dates of birth (DoBs) for accounts by the end of the second calendar year following the year in which the accounts were identified as Reportable Accounts.


In the event the FI does not have the TIN for an account, then for FATCA reporting, the FI must use the U.S. Internal Revenue Service (IRS) TIN placeholder codes. The updated DITC Portal User Guide (see pages 57-59) provides guidance on how to use the TIN placeholder codes.


Reporting FIs must include the DoB for all individuals included as reportable persons in CRS reporting and the TIN for all CRS reportable persons. The DITC reminded FIs there are very limited exceptions to including the DoB and TIN in CRS reporting. These exceptions may be found in the DITC's Explanatory Note regarding DoBs and TINs.


CRS: Y2022 Reportable Jurisdictions

The DITC reminded FIs the updated CRS Reportable Jurisdictions list was previously published.

Portal Deregistrations

The DITC portal has been updated to deregister / deactivate an FI. Deregistration is permitted where the entity has ceased to exist or is otherwise no longer a Cayman Reporting FI. The Principal Point of Contact (PPoC) must complete a form to request deregistration. The DITC Portal User Guide has been updated (see pages 24-25) to provide guidance on how to complete the form.


Prior to submitting the form, the PPoC must ensure reporting obligations for each year the FI had reporting obligations have been completed including:

  • FATCA Return

  • CRS Return

  • CRS Filing Declaration

  • CRS Compliance Form

The PPoC must provide evidence of dissolution such as:

  • Certificate of Dissolution, Strike-Off, or equivalent

  • Trust deed that clearly indicates the FI name and date of termination

  • Directors’ resolution to terminate a cell of an SPC

Note that an entity in liquidation is not a dissolved entity.


If the reason for deregistration is a change in FATCA/CRS classification, the PPoC must provide a letter including the following:

  • Reason why the entity was initially classified as an FI based on the definition of that term in FATCA or CRS;

  • Reason why the entity is no longer an FI and from what date;

  • New classification; and

  • Evidence supporting the claim, such as termination of an investment management agreement or self-certification forms.

All deregistration requests must provide contact information for the person retaining the FI’s records for 6 years following the date of portal deregistration.


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


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