Cayman Islands FATCA And CRS Update – December 2016

FATCA - Sponsored Entities

Sponsored investment entities resident in a jurisdiction that has entered into a Model 1 intergovernmental agreement with the United States for FATCA (such as the Cayman Islands) that have US reportable accounts must be registered by their sponsoring entity with the IRS to obtain a GIIN by 31 December 2016. Cayman Islands sponsored investment entities that do not currently have (or have not had) US reportable accounts are not required to have a GIIN by this date but if US reportable accounts are identified then sponsors should obtain a GIIN within 90 days of first identifying such accounts. Cayman Islands sponsored investment entities should ensure that they select "Non-Reporting IGA FFI" on any W-8BEN-E forms and not "Sponsored FFI".