Cayman Islands Extend FATCA Compliance Deadlines

On May 11, 2015, the Cayman Islands announced the extension of its FATCA registration and reporting deadlines, as follows:

Registration

Each Cayman Islands investment entity that has been classified as a “Reporting Cayman Islands Financial Institution” for purposes of FATCA (or its “sponsoring entity,” if applicable) should register with the Cayman government by the extended May 12, 2015 deadline in order to comply with its obligations under FATCA, regardless of whether it will be required to file a 2014 FATCA report with the Cayman government.

Reporting

Despite its earlier statement that the filing deadline for 2014 FATCA reports would not be extended beyond May 31, 2015, the Cayman Islands Department for International Tax Cooperation (“DITC”) announced that the reporting deadline would, in fact, be extended to June 12, 2015. Accordingly, each Reporting Cayman Islands Financial Institution (or its “sponsoring entity”) that has a reporting obligation with respect to 2014 now has until June 12, 2015 to file its 2014 FATCA report. “Nil reporting” is not required if a Reporting Cayman Islands Financial Institution had no reportable accounts in 2014.