FATCA Update: Investment Fund Registration and Reporting with the Cayman Islands Government

Cayman Islands-based investment funds and other Cayman financial institutions (collectively "Cayman Fls") should be aware that such Fls are required to register with the Cayman Islands Tax Information Authority ("Cayman TIA") no later that April 30, 2015. Such registration requirements are contained in Cayman Islands regulations issued under the Intergovernmental Agreement between the United States and Cayman Islands for the implementation of the provisions of US law known as the Foreign Account Tax Compliance Act ("FATCA").  The original deadline for registration with the Cayman TIA was March 31, 2015 but this deadline was extended to April 30, 2015 in an announcement released February 23, 2015.

Registration.  The Cayman Islands government anticipates that Cayman Islands funds and other FIs will be able to register via the Cayman TIA's online registration portal beginning in early March.

Reporting.  Cayman Islands financial institutions will also use the Cayman TIA's portal to submit annual reports with respect to their "U.S. reportable accounts" required under FATCA. Cayman Islands financial institutions should submit their reports relating to the 2014 calendar year by May 31, 2015.

If you have additional questions, please reach out to your Sadis & Goldberg contact for further clarification.

Cheryl Spratt