Urgent Reminder Regarding Cayman Island Reporting Requirements Under CRS
In December 2016, the Cayman Islands introduced amendments to the regulations implementing the Common Reporting Standard ("CRS") in the Cayman Islands (as amended, the CRS Regulations). The CRS Regulations require all Cayman Islands Financial Institutions ("CFIs"); Cayman Reporting Financial Institution ("CRFIs") and Non-Reporting Financial Institutions ("NRFIs") to submit to the Cayman Islands Tax Information Authority ("TIA") by June 30, 2017. This Information Notice ("Notice") requires stating the legal name of the fund at issue, its TIA issued ID number (if available) and contact information for both an Authorized Person ("AP") and a Principal Point of Contact ("PPOC") (or, Responsible Officer" in IRS parlance) - the AP and PPOC cannot be the same person. The PPOC will be the principal point of contact for TIA related matters and the AP will be the sole person authorized to change or update the PPOC or related PPOC information included on the Notice.
The Notice must be completed, signed by a fund director and filed with the TIA by June 30, 2017.
In addition to the filing of the Notice, all CFIs, CRFIs and NRFIs are required to report certain information regarding the relevant fund entities to TIA by July 31, 2017 even if they have no information to report (a "NIL Report").
The TIA has introduced penalties up to (US) $50,000 if these obligations are not satisfied. If applicable, you should discuss the requirements with your directors and administrators.