FATCA Reporting Obligations In The British Virgin Islands

British Virgin Islands entities who have determined that they are Reporting BVI Financial Institutions ("Reporting FIs") for the purposes of the Foreign Account Tax Compliance Act of the United States ("FATCA") and recently registered with the US Internal Revenue Service ("IRS") for a Global Intermediary Identification Number ("GIIN") should now be taking steps to identify any accounts they hold for which information will need to be reported to the BVI International Tax Authority ("ITA") for onward transmission to the IRS. 

The account identification process will require a due diligence exercise to be undertaken to determine: 

1. which financial accounts may be exempted from reporting by virtue of their nature, or their de minimis account value thresholds;