Recently there have been a number of updates to the FATCA and CRS guidance issued by the IRS, OECD and Irish Revenue. Many of these updates will affect the upcoming returns due at the end of June, while others apply to overall compliance. FATCA reporting continues to evolve in this third year of reporting and 2017 marks the first year of CRS returns being due which comes with its own unique challenges.
Compliance with all aspects of FATCA and CRS requires a robust operational process as well as diligent monitoring of updates to and interpretations of available guidance. Audit programmes are being discussed and rolled out by Revenue authorities worldwide, therefore Financial Institutions would be wise to perform compliance health checks and implement remediation plans as necessary.
The most up to date OECD CRS FAQs can be found on the OECD portal.
Please continue to be diligent about updates and changes to guidance as further FAQ updates are expected from Revenue. If you would like to discuss these updates or how EY can assist you in fulfilling your FATCA and CRS requirements please reach out to me or your EY contact at any time.