CRS and FATCA Reporting deadline extension and NEW Information Requirements

FATCA – All Model 1 Countries: Including BVI, Bermuda and Cayman Islands

Bermuda and BVI

The IRS has provided for an extension of time for Model 1 IGA jurisdictions to provide their 2019 FATCA data to the United States competent authority.

Currently the reporting deadline for the BVI is 31 May 2020 and the reporting deadline for Bermuda is 15 July 2020.

Cayman Islands

The new Cayman Islands Department for International Tax Cooperation (DITC) Portal for CRS FATCA reporting will now launch in June 2020 and all functionality will be available at that time.

As a result of this change by the US competent authority, the DITC is now extending the FATCA reporting deadline for the 2019 reporting period to 16 November 2020.

CRS (Cayman Islands)

Due to applicable international deadlines being extended and in order to bring the reporting deadlines in line, the DITC is now extending the CRS reporting deadline for the 2020 reporting period to 16 November 2020 as well.

Cayman Islands CRS Compliance Form

The DITC released a new CRS Compliance Form on 15 April 2020 as part of overall compliance with CRS. The CRS Compliance Form requires Cayman Islands Reporting FIs to collect additional information for the following sections and submit the form via the DITC Portal which, as mentioned above, will be available in June 2020:

Financial Institution Data Profile

Financial Account Data, including information and classification of type of Non-Reportable Accounts

AML/KYC and Accounting (where applicable)

CRS Due Diligence Process

The deadline for the submission of this form is expected to be 15 September each year.

In order to provide sufficient time to collect the additional information and complete the form, the deadline for the 2019 reporting period will be 31 December 2020.

For more information on any aspect of this briefing please contact any member of the Marbury team.

Overview of FATCA & CRS

The US Foreign Account Tax Compliance Act (FATCA) and Common Reporting Standards (CRS) have far-reaching implications on many entities across the globe. FATCA, implemented by the Internal Revenue Services (IRS), promotes cross-border tax compliance and was implemented to reduce offshore tax evasion by US persons holding assets through offshore accounts. Similarly, CRS was developed by the Organisation for Economic Cooperation and Development (OECD) and it is also a global reporting standard for the automatic exchange of information (AEOI).

US FATCA has the greatest implications on foreign entities that fall under the definition of a financial institution (FI). Jurisdictions that have a signed Inter-Governmental Agreement (IGA) with the IRS are classified as either Model 1 or Model 2 jurisdictions.

Hong Kong and Singapore are classified as Model 2 IGA jurisdictions. Bermuda, BVI and Cayman Islands are Model 1 IGA jurisdictions and therefore are classified as Participating Jurisdictions. Participating Jurisdictions under CRS and FATCA have certain requirements all FIs must abide by, including notification and reporting obligations, however these requirements differ depending on whether the jurisdiction has a Model 1 or a Model 2 IGA.

You or your company may be eligible to report.  Please contact us if you need related information or require assistance regarding CRS FATCA Reporting.


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