Sovos Kicks Off Networking Series: CRS Expected to Increase Reportable Accounts Fivefold

Scott Freedman
October 5, 2016


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).


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.

AEOI Reporting Operating Framework

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.

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Scott Freedman

Scott Freedman is Director of Product Strategy for AEOI solutions at Sovos. Scott has over 15 years of experience in strategic marketing and product strategy. He has worked for business-to-business software and SaaS solution companies like Thomson Reuters and with Fortune 500 companies as a business consultant. Scott has a background in law and earned his J.D. and undergraduate degrees from the University of Chicago and University of Illinois.
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