CRS and FATCA expert

Have You Been Tricked by your CRS Regulator Like This?

Peter Cotorceanu CRS, CRS Regulator, FATCA

Most fiduciaries are conscientiously trying to comply with FATCA and CRS as best they can. Therefore, it’s more than a little frustrating when regulators try to change the rules mid-stream—and in ways not authorised by local law. In a couple of CRS countries, regulators have purported to impose obligations on Financial Institutions (FIs) that go beyond what local law requires. …

CRS and FATCA expert

Hey FFI Agreement, what’s new?

Peter Cotorceanu FATCA, FFI Agreement

As set forth in the last blog, the deadline for the renewal of FATCA FFI Agreements is pending and all affected FIs must submit their renewal application by the end of July or risk removal from the FATCA GIIN List. (Remember, though, that not all FIs with GIINs have to renew—check the last blog for details.) While the offer to …

CRS and FATCA expert

Time to Renew the FFI Agreements

Peter Cotorceanu Blog, FATCA, FATCA Entity Classification

Upon registration for a GIIN via the IRS FATCA Registration Portal, certain FIs (i) subject to a Model 2 IGA, or (ii) not subject to any IGA automatically entered into a contract with the IRS known as the FFI Agreement. The FFI Agreement sets forth the FI’s rights and responsibilities (with responsibilities outnumbering rights heavily). In the scrum of FATCA …

Panama Antes Up: AEOI Regulations Published

Peter Cotorceanu Blog, CRS, FATCA, OECD

The relationship between Panama and international tax transparency has proved a bit tumultuous over the past two years (or hadn’t you heard?). As a result, the country’s release of FATCA and OECD CRS regulations on 12 May (available here) prompted considerable curiosity (in me anyway) as to Panama’s chosen approach. Unfortunately, my poor Spanish hampers any detailed analysis of the …

CRS and FATCA expert

URGENT: Do Fiduciaries Have to Register Their FATCA Sponsored Entities by 1 January 2017?

Peter Cotorceanu Blog, FATCA, FATCA Sponsored Entities

Many fiduciaries have recently received letters from banks and other financial institutions about their sponsored entities under FATCA. These letters generally take one of two forms. The first either implies or outright states—incorrectly—that all sponsored entities must register with the IRS and obtain their own Global Intermediary Identification Numbers (GIINs) by 1 January 2017. The second type of letter says …