The Department for International Tax Cooperation (DITC) of the Cayman Islands announced updates for both FATCA and CRS reporting in response to the COVID-19 pandemic. The DITC:
Extended the FATCA reporting deadline for the 2019 reporting period to 16 November 2020.
Released a new CRS compliance form with the 2020 submission deadline of 31 December 2020. Note that the CRS reporting deadline for the 2019 reporting period is unchanged and remains as 18 September 2020.
For additional information, please refer to the Cayman Island Industry Advisory: Cayman Islands Industry Advisory
In addition, over the last week and in response to the COVID-19 virus, the IRS added new FAQs providing the following:
Reporting FAQ 5 provides an extension of time for Model 1 IGA jurisdictions to provide their FATCA data for tax year 2019 to the U.S. Competent Authority to 31 December 2020. added 14 April 2020.
Reporting FAQ 4 provides an extension of time for a Reporting Model 2 FFI or Participating FFI to file the FATCA Report (Form 8966) to the IRS from 31 March 2020 to 15 July 2020. There is no need to file a Form 8809-I, Application for Extension of Time to File FATCA Form 8966. This extension applies to other entities that have a FATCA Report filing obligation as well (e.g.,U.S. Withholding Agents or Direct Reporting NFFEs). updated 20 April 2020.
Registration Update FAQ 18 explains that an FFI with a registration status of "Agreement Terminated" has this status because the IRS identified an issue with its registration. These FFIs should review their registration message board for additional information. Further, entities that with a terminated registration and Global Intermediary Identification Number (GIIN) removed from the FFI List due to noncompliance with thenFATCA certification requirement must not register again for a new GIIN. The IRS reviews the GIIN list for terminated FFIs and will not approve their new registration status. Entities that need to reinstate their GIIN must contact the IRS's Foreign Payments Practice (FPP) by mail or email to apply for reinstatement and follow the outlined Procedures for FATCA Certification Event of Default Notices. This new manual described the FPP process for addressing noncompliance with the FATCA certification requirements including the Event of Default Notice timeline, the request for reconsideration process, and the remediation plan guidance. added 15 April 2020.
For additional information, please refer to the IRS FAQs using the following link: IRS FAQs
Stay up-to-date by signing up for our bi-weekly articles by visiting www.complypro.com. Scroll to the bottom of the webpage and you will see a ‘Sign Up’ option for the bi-weekly articles.