FATCA And Trustees: Part II

This update is a follow-up to our update entitled FATCA and Trustees: Part I ("Part I"), published in December 2014. 

Defined terms and abbreviations not otherwise described herein have the same meaning given to them in Part I. 

Since Part I was published, there have been a number of developments in both the Cayman Islands and British Virgin Islands ("BVI"). 

Revised Cayman Islands Guidance Notes 

On 15 December 2014, the Cayman Islands Tax Information Authority ("Cayman TIA") issued the second official version of the Cayman Islands FATCA Guidance Notes.¹  Of particular interest: 

(a)    A trust with an individual trustee resident in the Cayman Islands is now stated to be a Cayman Islands trust (in addition to corporate trustees which are incorporated, resident or licensed in the Cayman Islands).