Self-Certifications Required from Investors Subscribing to Cayman Islands (and Other non-U.S.) Investment Funds on or After January 1, 2016

The Cayman Islands (along with the United Kingdom, Ireland, Jersey, Guernsey, the British Virgin Islands and over 70 other countries) has committed to implementing the OECD Common Reporting Standard ("CRS"), which will require investment funds to collect tax identification information from all new subscribers and transferees who become investors on or after Jan. 1, 2016. The CRS is a new global tax information exchange regime that requires certain investment funds to obtain "self-certifications" from investors to permit reporting of their identity and tax residence to local tax authorities. The Cayman Islands Department for International Tax Cooperation ("DITC") published self-certification forms that can be used to collect the information required under CRS from individual and entity investors in Cayman Islands investment funds. Fund managers should consider updating their subscription process to comply with CRS diligence and reporting requirements going forward. Investment funds have 90 days from the subscription date to collect the necessary self-certifications. To view the announcement from DITC and the Cayman Islands self-certification forms, click here: http://www.tia.gov.ky/pdf/CRS/Common_Reporting_Standard_%28CRS%29_Updates_-_8Dec2015.pdf

If you have questions about this Alert, please contact Lance Friedler at 212.573.8030 or lfriedler@sglawyers.com.

Cheryl Spratt