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Mar 03, 2015

Offshore Hedge Funds and Other Investment Companies to Benefit From the FATCA Data Exchange

Featuring Paul Dailey

The Cayman Islands Department for International Tax Cooperation (DITC) has announced that it is in the final stages of testing its Automatic Exchange of Information (AEOI) portal, which is expected to be operational this month.
 
The AEOI portal will be used to exchange FATCA (Foreign Account Tax Compliance Act) data and will be used for registration and reporting by or on behalf of financial institutions. Financial institutions and financial intermediaries that are most affected by this would be offshore hedge funds and other investment companies.
 
On Nov. 29, 2013, the U.S. signed a Model 1 IGA (Intergovernmental Agreement) with the Cayman Islands in order to implement FATCA. Reporting financial institutions, including investment funds, will satisfy their Chapter 4 requirements by reporting specified information about U.S. accounts to the DITC, followed by an automatic exchange of such information with the U.S.
 
The deadline for registration was initially March 31 of the relevant calendar year. The DITC also announced that the registration deadline was extended to April 30, 2015. The reporting deadline, however, remains May 31, 2015.
 
The DITC also stated that the reporting format will be consistent with current published schemas by the IRS for U.S. FATCA and by the OECD (Organization for Economic Co-operation and Development) for the Common Reporting Standard, and will be in XML format. For further reference, we have included the following link to the Cayman Islands Department for International Tax Cooperation site.
 
http://www.tia.gov.ky/pdf/AEOI_News_&_Updates.pdf

 
If you have any questions regarding this alert, please contact a member of the International Tax Services Group or your Financial Services tax partner at Citrin Cooperman.