Cayman Islands has announced that it will accept Cayman FATCA and CRS reports (which were originally due on May 31, 2019) through July 31, 2019 and that these late returns will not be subject to any adverse consequences for late filing. The announcement provides much needed relief for Cayman financial institutions (FIs) still scrambling to gather and compile reportable data on investors.
Of course, FIs are still encouraged to file reports as soon as possible, but in light of increased enforcement efforts by Cayman, companies should use the additional time to obtain or confirm any missing or inconsistent data it has for customers and investors.
Cayman has also published an updated version of its AEOI Portal User Guide, Version 5.0 dated April 2019 (See user guide). The guide features a new section with Frequently Asked Questions as well as new guidance for handling error messages, notices from the Internal Revenue Service (IRS), and CRS status error notifications. It also includes more detailed guidance on when taxpayer identification numbers (TINs) must be included for reportable investors or accountholders on FATCA and CRS reports. Specifically, it clarifies that the TIN field should not be left blank if the account holder is a specified U.S. person (such as an individual), and must instead be entered as a preexisting account, with nine capital “A” characters. Otherwise, if left blank the account will be considered recalcitrant, which opens the door for compliance reviews and penalties.
For more details on Cayman’s requirements, please click here.
Also, to learn more about RSM’s FATCA and CRS Reporting Services, please refer to our FATCA page.