Important CRS Deadline and FFI Agreement Renewal Notices

Reminder: Upcoming Deadline for the Common Reporting Standard

As indicated in our newsletter sent on June 9th, the deadline for Common Reporting Standard (CRS) notification is Friday, June 30, 2017.

Any Cayman Islands funds that have not completed the required notification on the Cayman Islands AEOI Portal must do so by Friday, June 30, 2017.

IRS FATCA Registration System and FFI Agreements

We have become aware that many Cayman Islands funds have incorrectly received notices by e-mail from the IRS that an FFI agreement renewal is required.

Cayman Islands funds have generally not entered into FFI agreements with the IRS because they comply with the intergovernmental agreement between the United States and the Cayman Islands. (Certain Cayman Islands funds may have branches in jurisdictions that have not entered into an intergovernmental agreement with the United States, and in those cases an FFI agreement with the IRS is required, but this would be rare.) The reminder appears to have been inadvertently sent by the IRS to all funds, including funds for which an FFI agreement renewal is not required (such as Cayman Islands funds managed in the United States). If you have any questions about how to respond, please contact us.