May 2024 | Issue 11

Comply Connect

Designed to not only keep you up to date with all things information reporting, but also to provide valuable insights into what lies ahead in the upcoming month. 

Coming Up in June

Discover the U.S. information reporting and withholding obligations you should keep an eye on in the coming month.

Key Updates

Explore the Key updates provided by the IRS and other tax authorities from the last month you should be aware of.

FATCA & CRS Headlines

Take a look at our breakdown of the latest FATCA & CRS headlines to keep you up to date.

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CEO Profile (David Marley

A message from our cEO:

As we move from the bustling activity of April and May into the hopefully more relaxing days of June, we can all start to breathe a sigh of relief and look ahead. This is a good time to focus on the future, not only in adapting to regulatory changes but also in advancing our technology. At Comply Exchange, we pride ourselves on being a forward-thinking, innovative software development company. Our R&D team has been delving deeper into the exciting world of artificial intelligence, introducing new products and expanding our capabilities with GenAI. Stay tuned for an exciting new product announcement next month!

In the meantime, we’ve been particularly focused on integrating Copilots. These new tools have the potential to significantly improve user experience and productivity, especially with Microsoft’s strong commitment to them. They not only enhance our offerings but also make the daily work more engaging and interesting, bringing you closer to the forefront of innovation. Early results indicate these additions could be game-changing for our industry.  Stay tuned for more updates and join us in exploring these exciting new possibilities.

Simplify. Collect. Comply.

David Marley | CEO

CEO Profile (David Marley

Coming up in June

EEI International Tax & Information Reporting Conference

We are excited to announce that we will be attending the EEI International Tax & Information Reporting Conference being held in New York from June 5 – June 7. This will be a great opportunity for us to showcase our latest innovations and listen to sessions hosted by key industry leaders, as well as connect with friends, partners and our clients. Stop by our booth to say hello and learn more about what all Comply has to offer.

British Virgin Islands: CRS Live Seminar

On June 5, 2024, the International Tax Authority (“ITA”) of the British Virgin Islands is hosting a live seminar for custodial institutions, depository institutions, and specified insurance companies subject to the reporting requirements under CRS. Registration closes on May 31, 2024.

Guernsey: FATCA and CRS Filing Reminder

As a reminder, since June 30, 2024, falls on a weekend this year, the deadline for Reporting Guernsey Financial Institutions (“RGFIs”) to submit both FATCA and CRS reports via the IGOR system is Monday, July 1, 2024.

Ireland: FATCA and CRS Filing Reminder

Irish Financial Institutions must submit both their FATCA and CRS reports by June 30. Ireland Revenue will exchange FATCA information with the U.S. and CRS information with the participating jurisdiction of tax residence of the account holders by September 30.

Isle of Man: FATCA and CRS Filing Reminder

Isle of Man Financial Institutions must submit both their FATCA and CRS reports by June 30. CRS and FATCA files must be sent to the Assessor using the Information Providers’ Online Service.

Jersey: FATCA and CRS Filing Reminder

Jersey Financial Institutions must submit both their FATCA and CRS reports for RY 2023 by June 30. The Government of Jersey will have support personnel available on June 29 and 30 to assist with any urgent queries.

Luxembourg: FATCA and CRS Filing Reminder

Luxembourg Financial Institutions are required to file both their FATCA and CRS reports to the Administration des contributions directes (“ACD”) by June 30. The transfer of data to ACD is done exclusively via a secure channel.

May 2024 Key Updates

Form 1099-DA 

On April 18, 2024, the IRS released the draft version of the Form 1099-DA, Digital Asset Proceeds From Broker Transactions. 

  • There are not many significant differences between the data on the draft Form 1099-DA and the Form 1099-B. 
  • The IRS is requesting comments, and any comments should be received by June 21, 2024. 

May 2024 FATCA & CRS Headlines

OECD: Updated CRS FAQs

The OECD released updated CRS-related Frequently Asked Questions. Updates include:

  • Due Diligence Requirements FAQ 27: Reliance on publicly available information
  • Non-Reporting Financial Institutions FAQ 5: Qualified Credit Card Issuer
  • Financial Account FAQ 13: Financial Accounts in the context of CFD trading activities

Bermuda: CRS Filing Deadline Reminder

The Bermuda Ministry of Finance published a notice reminding Bermuda RFIs of the upcoming submission deadlines for the 2023 CRS Filings and 2023 Annual CRS Compliance Certification Form (“CRS Compliance Form”).

  • CRS Filings: Must be submitted by all Bermuda RFIs and Trustee-Documented Trusts (“TDTs”) no later than May 31, 2024.
  • CRS Compliance Form: All Bermuda RFIs and TDTs must submit the CRS Compliance Form no later than September 30, 2024.

Penalties may apply for failure to submit the filings by these statutory deadlines.

The Ministry also posted key points and reminders regarding CRS compliance, which will be monitored and strictly enforced, including:

  • Primary Users
  • Deactivation Requests
  • Undocumented Accounts
  • Taxpayer Identification Numbers (“TINs”)
  • Dates of Birth
  • Addresses
  • Residence/Citizenship by Investment (RBI/CBI) Schemes

Bermuda: Updated CRS Independent Compliance Review Guidelines

On May 15, 2024, the Bermuda Ministry of Finance published an updated version of the CRS Independent Compliance Review Guidelines Version 2.0.

British Virgin Islands: BVIFars Portal Update

On May 22, 2024, the ITA of the British Virgin Islands published a notice reminding all BVIFars portal users that the payment feature of the portal is not yet active. Due to the payment feature not being operational, the current payment deadline is not applicable. RFIs should continue to fulfil filing obligations by the deadline and disregard the system-generated payment notification until further notice.

Finland: FATCA and CRS Corrections

On May 15, 2024, the Finnish Tax Administration published a newsletter regarding corrections to FATCA and CRS annual returns. Corrections can be made for 2023 returns by submitting a new annual information return by 31 July 2024. The new return replaces the previous return in full.

The newsletter also reminds of the importance of reporting account holders’ and controlling persons’ identifiers accurately on the returns, as well as a reminder to pay attention to missing U.S. tax identification numbers. Financial institutions must continue to make efforts to obtain missing TINs.

Singapore: 2023 FATCA and CRS Filing Deadline Reminder

As a reminder, all Reporting SGFIs must submit their 2023 FATCA and CRS returns to the Inland Revenue Authority of Singapore (“IRAS”) by 31 May 2024. Enforcement actions will be taken against Reporting SGFIs that do not submit their FATCA and CRS returns on time.

Singapore: CRS Entity Classification Self-Review Toolkit

On May 6, 2024, the IRAS published a notice indicating that the CRS Entity Classification Self-Review Toolkit has been updated to allow the performance of the self-review process online. The toolkit allows entities to determine their CRS entity classification and check if the entity is required to register for CRS.

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Comply Exchange was built to give businesses and individuals alike the support that they need to comply with the complex and ever-evolving regulatory tax burdens imposed by the IRS and other global authorities with respect to information reporting and withholding.

Reach out to our experts today to schedule a demo and see how our software and services can help you streamline and automate your tax compliance needs.