Are You Caught In The CRS "Triangulation Problem"?

The Common Reporting Standard ("CRS"), following along the precedent set by the Foreign Account Tax Compliance Act ("FATCA"), creates the concept of "accountholders" in structures such as trusts, foundations, companies and partnerships when those entities are "managed by" other financial institutions (e.g. professional trustees, corporate service providers, etc.). When such structures are the named entity accountholder at a bank or other financial institution, confusion and chaos often/sometimes ensues.

Confusion most commonly arises for the beneficial owners who have always considered the entity as the traditional "accountholder". They are correct in their understanding, but the confusion arises due to their lack of awareness of the new terminology.