On April 9, 2019, the Cayman Islands government issued an industry advisory extending the filing deadline for the 2018 US Foreign Account Tax Compliance Act (FATCA) and the Common Reporting Standard (CRS) from May 31, 2019, to July 31, 2019.
Impact On Filers
The filing extension only applies to submission of the reporting file, not the filer registration deadline. That means all 2018 first-time filers must still complete their registration in the Cayman Islands Portal by no later than April 30, 2019.
Next Steps
Although the Cayman Islands FATCA and CRS reporting requirement has been in place for several years, preparing the reporting file can be burdensome, resulting in last-minute preparation.
To prevent filing complications, financial institutions (FIs)—such as banks and funds—that are domiciled in the Cayman Islands can use the upcoming months to make sure all 2018 active financial accounts are properly documented and classified for purposes of FATCA and CRS.
Report Preparation
Determining your reportable population for FATCA and CRS is most commonly done through collecting and reviewing self-certifications or Forms W-8 or W-9. While potentially appearing to be an easy task, collecting and reviewing documentation provided by account holders can be time intensive.
By using the additional time given by the Cayman Islands, FIs can place themselves in a good position to file ahead of the deadline. The extension will also allow FIs adequate time to ask questions of outside service providers or collect necessary information from account holders in advance of the reporting deadline.
While the deadline extension provides filers with additional time to prepare, this task shouldn’t be put off for too long. The Cayman Islands government urges all filers to submit their reporting as soon as it’s ready. This can help filers avoid potential portal access issues, which have historically occurred closer to the reporting deadline.
We’re Here to Help
For more information about how this update could affect you or your business, contact your Moss Adams professional or email inforeportingwithholding@mossadams.com.