As an update to our US FATCA, CDOT and CRS alert, the Cayman Islands Government has issued a further industry alert, confirming that the Automatic Exchange of Information Portal (the "AEOI Portal") is now open and a revised AEOI Portal User Guide (the "User Guide") is available.
Notification Obligation: US FATCA and CRS
Cayman Financial Institutions are reminded that US FATCA and CRS Notifications must be completed by 30 June 2017. In order to complete notification obligations under US FATCA and CRS, every Cayman Financial Institution is required to prepare a new letter of authorization based on the DITC template.
Reporting Obligations under US FATCA
Reporting under US FATCA must be completed by 31 July 2017. The US FATCA reporting function is now available on the AEOI Portal.
The DITC has confirmed that Cayman Financial Institutions should not attempt to address any IRS notifications in respect of 2014 and 2015 US FATCA Returns until further guidance is issued from the DITC and that such institutions will not be deemed to be in contravention of their US FATCA obligations when following this instruction. The DITC plans to publish: (i) a revised User Guide to explain how Cayman Financial Institutions must address IRS notifications and (ii) email specific guidance on how to resolve particular types of IRS notifications for 2014 and 2015 US FATCA Returns to the Principal Point of Contact of affected Cayman Financial Institutions.
Reporting Obligations under CRS
Reporting obligations must be completed by 31 July 2017. The CRS reporting function is not currently available on the AEOI Portal.
The DITC will be issuing a further industry advisory in mid-June with details of: (i) a revised version of the User Guide with details on CRS Reporting and (ii) details of when the CRS reporting function will be available on the AEOI Portal.
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