The deadline for compliance with both US FATCA and UK FATCA fast
approaches.
Cayman entities which are classified as Financial Institutions
are within the scope of FATCA. A typical Cayman fund will fall
within the definition of a Financial Institution, however there are
many other Cayman entities and structures which may be caught by
the FATCA definition which is wider than the normal meaning of the
expression.
All Cayman entities should consider their classification for
FATCA purposes. Classification can be a difficult exercise and
further guidance is available from Harneys if required. In most
cases, we can provide a fixed quote for provision of this
service.
In relation to US FATCA, entities which fall within the
definition of a Financial Institution but which have either no US
sourced income and/or no Specified US Persons (as defined under
FATCA) as shareholders, partners, unitholders, investors, or other
account holders (each an "investor") will still need
