Structured Finance: FATCA And The OECD Common Reporting Standard

More than 90 jurisdictions, including all 34 member countries of the Organisation for Economic Co-operation and Development ("OECD") and the G20 members, have committed to implement the Common Reporting Standard for automatic exchange of tax information ("CRS"). Building on the model created by FATCA, the CRS creates a global standard for the annual automatic exchange of financial account information between the relevant tax authorities.

The major structured product issuer jurisdictions, including the British Virgin Islands, Cayman Islands, Ireland, Luxembourg and the Netherlands, are among a group of over 50 jurisdictions known as the "Early Adopters Group" that have committed to the implementation of the CRS by the end of 2015 and the first exchanges of information in 2017. In terms of the number of potential reporting financial institutions under CRS, the membership of the Early Adopters Group is significant (e.g. financial institutions in the Cayman Islands and