Centaur offers U.S. FATCA (Foreign Account Tax Compliance Act), U.K. FATCA and OECD Common Reporting Standard (CRS) compliance services to its clients including:
- Registration of funds as Foreign Financial Institutions (“FFI’s”) with the US Internal Revenue Service (“IRS”)
- Establishment and maintenance of FATCA/CRS status for investors
Acting as Responsible Officer (“RO”) and Point of Contact (“POC”), as required, for both the IRS and Local Competent Authority (“LCA”)
- Reporting to the IRS or LCA
Ongoing compliance monitoring and reporting
U.S. Internal Revenue Service (“IRS”) Portal: Centaur completes the online registration on behalf of the fund to obtain the necessary Global Intermediary Identification Number (“GIIN”). This is required for both Model 1 and Model 2 Intergovernmental Agreements (“IGA”) funds. For Model 1 IGA funds (e.g. Cayman, BVI and Irish funds) and for CRS purposes, Centaur also registers the fund with the LCA.
INVESTOR FATCA CLASSIFICATION
Centaur conducts initial and ongoing reviews of investor data and compiles the necessary documentation and information to establish investor FATCA/CRS status.
Centaur acts as a Responsible Officer (“RO”) and Point of Contact (“POC”) for both IRS and LCA enquiries:
- Provision of a RO and POC for IRS enquiries: The IRS requires that a RO and POC are recorded. The RO and/or POC will deal with all IRS enquiries in relation to US FATCA.
- Provision of a POC for LCA: The Cayman, BVI and Irish tax authorities require the name and details of a Principal POC. This person will deal with all LCA enquiries in relation to FATCA/CRS.
Centaur will submit all necessary reports, certifications and filings, within the required timeframes, to the LCA or directly to the IRS, as applicable:
- Model 1 IGA registered funds (e.g. Cayman, BVI and Irish Funds): Centaur reports directly to the LCA for US and UK FATCA
- Model 2 IGA funds (e.g. Bermuda Funds): Centaur reports directly to the IRS and the UK HMRC for US and UK FATCA
For funds in scope for CRS, Centaur will report directly to the LCA.
ONGOING MONITORING AND REPORTING
Centaur continuously monitors investor accounts for any changes to FATCA/CRS status and reports, on a regular basis, to the board of directors of the fund on FATCA/CRS compliance.