ByKevin C. Butler, Craig T. Fulton From Conyers Dill & Pearman

Second Quarter Notification and Reporting Deadlines for Reporting Cayman Islands Financial Institutions

Reporting Cayman Islands Financial Institutions (“Cayman Islands FIs”) are reminded that 2015 is the first year in which they are required to report to the Cayman Islands Department for International Tax Cooperation. For a recap on the main provisions of FATCA and UK FATCA please see our alert entitled “Impact of FATCA on Cayman Islands Entities”.

Cayman Islands FIs should have a Global Intermediary Identification Number (GIIN)

Cayman Islands FIs should now have a GIIN. For more information on how to obtain a GIIN please go to the website here.

Notify the Cayman Islands Department for International Tax Cooperation on or before 30 April 2015

On or before 30 April 2015 each Cayman Islands FI is required to notify the Cayman Islands Department for International Tax Cooperation that they intend to make a report and include their name, FATCA categorization and GIIN.

Notification may be conducted by or on behalf of Cayman Islands FIs directly to the Cayman Islands Department for International Tax Cooperation via the Cayman Automatic Exchange of Information (AEOI) Portal.

It is anticipated that the Cayman AEOI Portal will be opened in early March 2015. Once activated, the Cayman AEOI Portal can be accessed from the website here.

Report to the Cayman Islands Department for International Tax Cooperation on or before 31 May 2015

On or before 31 May 2015 each Cayman Islands FI is required to report to the Cayman Islands Department for International Tax Cooperation in respect of US Reportable Accounts.

A NIL report is required even where the Cayman Islands FI has no US Reportable Accounts.

The reporting format will be consistent with currently published schemas by the IRS for FATCA and by the OECD for the Common Reporting Standard and will be in XML format. Cayman Islands FIs will have the option of submitting reports to the Cayman Islands Department for International Tax Cooperation individually, by entering information manually on the website, or via bulk ability to upload an XML file containing information for multiple Cayman Islands FIs.

Failure to report to the Cayman Islands Department for International Tax Cooperation could result in penalties and/or enforcement action.

Cayman Islands FIs Should Prepare Now

Cayman Islands FIs should now have a GIIN. Cayman Islands FIs should notify the Cayman Islands Department for International Tax Cooperation on or before 30 April 2015. Full reporting to the Cayman Islands Department for International Tax Cooperation must take place on or before 31 May 2015.

Reporting and notification for UK FATCA commences in 2016.

For further guidance on FATCA or UK FATCA please contact us.

This article is not intended to be a substitute for legal advice or a legal opinion. It deals in broad terms only and is intended to merely provide a brief overview and give general information.

SOURCE: http://www.conyersdill.com/publications/view/fatca-notification-and-reporting-are-you-ready

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