Overview
Sovos Compliance kicked off its networking series with in New York on September 22nd with an event focused on Automatic Exchange of Information (AEOI) reporting. The agenda included a panel discussion with Alex Crenshaw from Wells Fargo, Chris Liguori from State Street, and Josh Herrera from Morgan Stanley. Lani Chou (Pricewaterhouse Coopers) and Fred Cibelli (Ernst & Young) led a lively discussion of best practices and target operating models for AEOI reporting. And Kamela Nelan from the IRS and Rami Eldman (Ernst & Young) provided an overview of FATCA schema changes.
Highlights and Themes
Reporting Volume
Attendees predicted that the Common Reporting Standard (CRS) will likely increase the number of reportable accounts by five times the number of accounts that they currently report under FATCA.
The number of reportable accounts under the Foreign Account Tax Compliance Act (FATCA) is expected increase by four-to-five times under the Common Reporting Standard (CRS).
Process
Lani Chou outlined key success factors for developing AEOI reporting processes that included:
- Establishing a decision-making authority
- Agreeing on design principles
- Defining scope, roles, and responsibilities
- Establishing a change control process to integrate regulatory changes without disrupting day-to-day operations
- Developing a resource plan
Best Practices
Some CRS guidance may be unclear even within the same jurisdiction. Panelists suggested that financial institutions establish processes and consistently follow these processes to show regulators due diligence and intent to comply.
Fred Cibelli provided a compelling argument for combining and automating tax compliance operations to handle increased complexity.
Things to think about:
- Review your reporting jurisdictions
- Focus on data sourcing and mapping
- Be prepared for last minute changes
- Understand how this year’s reporting varies from other years
- Ensure you can support resubmission and post-submission
FATCA Schema Changes
The new FATCA Schema will take effect January 1, 2017.
- It remains to be seen which countries will adopt the new schema or retain the existing one.
- It’s likely to be a mix, so be careful as you prepare this tax year’s FATCA reporting.
Take Action
- Stay up-to-date on AEOI requirements and changes. To learn more about how a centralized AEOI solution can mitigate these common challenges, download the report.
