There are fund structures which utilize the sponsoring entity
concept to comply with the U.S. Foreign Account Tax Compliance Act
("FATCA") whereby the sponsoring entity agrees to perform
all required due diligence, withholding, reporting and other
requirements for FATCA purposes on behalf of its sponsored
entities. The sponsored entities can use the Global Intermediary
Identification Number ("GIIN") of the sponsoring entity.
From 1 January 2017 onwards, certain sponsored entities will no
longer be able to rely on the GIIN of the sponsoring entity and the
sponsoring entity will be required to obtain separate GIINs for
certain of its sponsored entities.
A sponsoring entity must register its sponsored entities that
are covered by a Model 1 Intergovernmental Agreement
("IGA") (i.e. Cayman Islands, BVI, etc.) by the later of
31 December 2016 or 90 days after an U.S. reportable investors is
first identified. Sponsored entities domiciled in jurisdictions
that are either
