New guidance clarifies the upcoming reporting rules for Canadian FIs.
While the detailed account information must be provided to the CRA beginning in 2018, affected financial institutions must have procedures in place to identify this information by July 1, 2017.
This guidance, which applies to Canadian entities that will be subject to the Common Reporting Standard (CRS), provides much-needed clarity in some areas, and addresses many of the concerns raised by a number of industry groups. Specifically, the guidance extends relief for client name accounts held by investment funds and dealers to client name accounts held by custodians and investment managers. Further, the guidance sets parameters under which financial institutions can rely on documentation collected by their agents to reduce their own documentation procedures, and reduces the number of controlling persons that must be reported for collective investment vehicles established as trusts in countries that are not participating jurisdictions for CRS purposes. However, some additional clarification would be welcome in certain areas, including whether reloadable payment cards can be treated as exempt accounts and how broadly to interpret certain comments made regarding using some U.S.-based Foreign Account Tax Compliance Act (FATCA) and CRS definitions interchangeably.
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