The Cayman Islands Tax Information Authority (the “TIA”) has recently extended the deadline to register on its AEOI Portal. The deadline is now May 29, 2015. The original deadline was March 31st, but has been extended several times.
Cayman Islands funds must also report certain information, including name, address, TIN, and account balance, on specified U.S. persons holding financial accounts (e.g., fund interests) to the TIA. The reporting deadline has been extended to June 26, 2015.
Offshore feeders and offshore master funds should have already (1) registered with the IRS and obtained a Global Intermediary Identification Number (a “GIIN”), (2) obtained (or be in the process of obtaining) W-8s and W-9s (and U.K. self-certification forms) from their investors, and (3) implemented required FATCA diligence procedures in respect of investors (including through an administrator).
The AEOI Portal will also facilitate UK FATCA registration and reporting, which is not required until 2016.
If you have any questions regarding FATCA or any other tax issues, please contact your primary Kleinberg Kaplan attorney or a member of our tax department.