UK FATCA And Cayman Funds

As noted in our prior update of 19 November 2013, the Cayman Islands government signed an intergovernmental agreement with the United Kingdom (the "UK IGA") on 5 November 2013.  The UK IGA provides a framework for the implementation in the Cayman Islands of a UK tax residents reporting regime ("UK FATCA") which is similar in scope to the US Foreign Account Tax Compliance Act ("US FATCA").  In that respect, the structure and scope of the UK IGA is very similar to the intergovernmental agreement which the Cayman Islands government signed with the US government (the "US IGA") to implement US FATCA.  Regulations to give effect to UK FATCA in Cayman Islands law were passed on 4 July 2014.