In recent months, the IRS has opened its information reporting portal and non-U.S. jurisdictions heavily affected by FATCA (e.g., Cayman Islands and British Virgin Islands) have issued official guidance to implement FATCA compliance for financial institutions in their respective jurisdictions.
The following list outlines upcoming FATCA compliance deadlines in 2015, as outlined by Kate Forde, Compliance Officer at Apex Fund Services :
*Deadlines for Cayman and BVI Financial Institutions
May 29, 2015: Cayman Islands Local Registration Deadline
Each Reporting Cayman Islands Financial Institution must register electronically with, and provide certain information to, the Cayman Islands Department for International Tax Cooperation (the “DITC”).
June 26, 2015: Cayman Islands 2014 FATCA Reporting Deadline
Each Reporting Cayman Islands Financial Institution must file a 2014 information return with the DITC.
Before June 30, 2015: BVI Local Registration Deadline
Each Reporting BVI Financial Institution that is required to file a 2014 FATCA report must register with the BVI Financial Account Reporting System, and such registration must be approved by the BVI International Tax Authority, before such Reporting BVI Financial Institution can submit its 2014 report (which must be done by June 30, 2015, see below).
July 31, 2015: BVI 2014 FATCA Reporting Deadline
*Deadlines for Reporting Financial Institutions in Model 1 Jurisdictions (other than Cayman/BVI)
May 31/June 30, 2015: 2014 FATCA Reporting Deadline
Generally Reporting Financial Institutions in other Model 1 jurisdictions must file any required 2014 FATCA reports with the relevant Tax Authorities by one of these dates.
July/August 2015: 2014 FATCA Reporting Deadline
Financial Institutions in Australia and Mauritius must file any required 2014 FATCA reports by 31 July 2015 and Bahamian Financial Institutions must file by 17 August 2015.