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ARTICLE · 12 AUGUST 2020

FATCA And CRS Compliance For Client Name Accounts

Borden Ladner Gervais LLP
Borden Ladner Gervais LLP
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Canadian financial institutions (FFIs) are subject to Canada's implementation of the Foreign Account Tax Compliance Act (FATCA) and the Common Reporting Standard (CRS) compliance regimes.

CanadaFinance and Banking

Canadian financial institutions (FFIs) are subject to Canada's implementation of the Foreign Account Tax Compliance Act (FATCA) and the Common Reporting Standard (CRS) compliance regimes. On July 10, 2020, the Canada Revenue Agency (CRA) released new versions of the FATCA Guidance and CRS Guidance (collectively, the Guidance).

The changes in the Guidance will significantly affect fund managers and dealers in the context of client name accounts (i.e., investment fund units sold through dealers issued in the name of the beneficial owner). The relevant changes relate to reportable accounts with missing foreign taxpayer identification numbers (TINs), and how the CRA imposes the resulting penalties against fund managers and dealers.

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