US FATCA And Cayman Funds: Due Diligence

On 29 November 2013, the Cayman Islands government signed a Model 1B (i.e. non- reciprocal) intergovernmental agreement with the United States of America (the "US IGA"). The US IGA provides a framework for the implementation of the US Foreign Account Tax Compliance Act ("FATCA") in the Cayman Islands. Cayman primary enabling legislation is expected to be enacted in early May 2014, with secondary legislation and guidance notes to be implemented in early July 2014.

In our two previous updates, we examined the rules relating to (i) entity classification under the US IGA for Cayman based Investment Entities, and (ii) GIIN registration and the need for a responsible officer for an Investment Entity. These updates can be viewed through the following links: