Latest Developments On FATCA And CRS Compliance

As discussed in our previous bulletins, the implementation of FATCA and CRS have fundamentally changed the compliance environment for Canadian financial institutions (FFIs) as they are expansively defined for purposes of Parts XVIII and XIX of the Income Tax Act (Canada) (ITA). On April 20, 2020, the Canada Revenue Agency (CRA) released long awaited amendments to both its CRS Guidance and its FATCA Guidance (collectively, the Guidance), which provide increased clarity on due diligence obligations and the associated penalties for non-compliance. In addition, on April 15, 2020, the CRA announced relief for FATCA and CRS information return filers amid the COVID-19 pandemic. This bulletin addresses both the April 15 and April 20 changes.