AEOI Compass Update: Week of Oct. 2, 2017

October 6, 2017

Changes to global FATCA and CRS compliance requirements happen frequently.  In order to provide customers with the updated and accurate information they need, Sovos documents each of these changes in its Compass portal. Here are some notable changes in AEOI reporting from this week.

New Zealand Updates Guidance Notes for Reportable Accounts and Collective Investment Vehicles

New Zealand’s Inland Revenue Department recently updated its FATCA Guidance Notes for both US Reportable Accounts and Collective Investment Vehicles.  No substantive changes have been made to either document.

To review the Notes for US Reportable Account, please follow this link.

To review the Notes for Collective Investment Vehicles, please follow this link.

IRS Releases Notice Detailing Procedures for Foreign FIs required to report U.S. TINs under FATCA Model 1 IGAs

The IRS recently released an advance version of Notice 2017-46 which details procedures for FFIs required to report U.S. TINs under FATCA Model 1 IGAs.  In this advance notice, the IRS establishes that they will not determine that there is significant non-compliance with reporting obligations under an applicable Model 1 IGA during calendar years 2017, 2018, and 2019 because of a failure to obtain and report each required U.S. TIN.  However, this will only occur provided that the reporting Model 1 FFI meets the following conditions:

  • Obtains and reports the DOB of each account holder and controlling person whose U.S. TIN is not reported
  • Requests annually from each account holder any missing required U.S. TIN; and
  • Before reporting that relates to calendar year 2017 to the partner jurisdiction, searches its electronic records for missing U.S. TINs.

The notice also provides a phase-in period for U.S. FIs to obtain and provide Foreign TINs from account holders for reporting under Form 1042-S. Further details will be published in a separate “What’s News” article.

For further details, please follow the link below.


Cayman Islands Closes AEOI Portal, Issues Statement on Late Filing

The Cayman Islands’ Department for International Tax Cooperation closed its AEOI portal on September 13.  The portal was originally scheduled to be closed on August 31 in line with the Department’s deadline for AEOI reporting, but the Department kept the portal open until September 13 to accommodate late filers.  The Department stated that it will reopen the portal to accommodate subsequent adjustments at some point in the future.

In addition, the Department also provided a statement indicating that it is working through a significant backlog of technical inquiries regarding the AEOI portal.  The Department expects to be able to respond to inquiries in its current backlog by October 16.  Inquiries sent in the interim will not be reviewed until after October 16.

The Department also stated that it will take under consideration the efforts made by financial institutions to complete their reporting obligations.  Where a financial institution may have been unable to file timely and emailed the Department, the Department will take these factors into consideration.

This information was published in the Department’s AEOI News & Updates, a link to which can be found below.


IRS Issues Reminder to Foreign Financial Institutions Regarding FATCA Registration Status

The IRS recently published a reminder to foreign financial institutions (FFIs) to renew their FFI agreements. In IR-2017-153, the IRS warns FFIs that if they do not complete their renewal of their FFI agreement by October 24, 2017, they will be treated as having terminated their FFI agreement as of January 1, 2017. This means any institutions who have failed to renew will be removed from the November FFI list, and subject to a 30% tax on certain U.S. source payments.

Please note that the FATCA FFI Registration System has been updated to include the ability for FFIs to renew their agreements with the IRS.

To review the IRS press release relating to this issue, please visit the IRS website by clicking here


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Sovos was built to solve the complexities of the digital transformation of tax, with complete, connected offerings for tax determination, continuous transaction controls, tax reporting and more. Sovos customers include half the Fortune 500, as well as businesses of every size operating in more than 70 countries. The company’s SaaS products and proprietary Sovos S1 Platform integrate with a wide variety of business applications and government compliance processes. Sovos has employees throughout the Americas and Europe, and is owned by Hg and TA Associates.
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