US FATCA And Cayman Funds: GIIN Registration

On 29 November 2013, the Cayman Islands government signed a Model 1B (i.e. non-reciprocal) intergovernmental agreement with the United States (the "US IGA").  The US IGA provides a framework for the implementation of the US Foreign Account Tax Compliance Act ("FATCA") in the Cayman Islands.  The process of preparing the relevant Cayman enabling legislation has now begun in earnest. 

In our previous update of 15 January 2014, we examined the rules relating to entity classification under the US IGA for Cayman-based Investment Entities.  In this update, we consider some of the issues surrounding the registration requirement set-out in the US IGA. 

Fund Industry - Registration