On March 22, 2017, the Canada Revenue Agency (CRA) issued the
long awaited "Guidance on the Common Reporting
Standard". The Common Reporting Standard (CRS),
which is formally referred to as "Standard for Automatic
Exchange of Financial Account Information in Tax Matters", is
contained in under Part XIX of the Income Tax Act
(the Act).
Within the publication are various commentaries that
cross-reference the U.S. Foreign Account Tax Compliance Act (FATCA)
contained in Part XVIII of the Act in the implementation of
CRS. Of note is the recognition that for the purposes of Part
XVIII, non-reporting financial institutions are listed in Annex II
of the IGA and are identified as exempt beneficial owners or
deemed-compliant financial institutions. Since CRS does not
contain the concepts of exempt beneficial owners and
deemed-compliant financial institutions, certain Canadian financial
institutions that do not have obligations under Part XVIII will
have obligations under
