Cayman Islands and U.S. Sign FATCA IGA

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On November 29, 2013, the Cayman Islands and the U.S. Signed a FATCA IGA. The Cayman Islands IGA is a Model 1B agreement, meaning that FFIs in the Cayman Islands will be required to report tax information about U.S. account holders directly to the Cayman Islands Tax Information Authority. The Cayman Islands Tax Information Authority will in turn relay that information to the IRS. Additionally, the United States and the Cayman Islands also signed a new Tax Information Exchange Agreement (TIEA), to take the place of the original TIEA signed in 2001. The IGA is non-reciprocal; the IRS will not report to the Cayman Islands on Caymanian account holders in the U.S.

U.S. taxpayers with foreign bank accounts should begin the process of coming into compliance with their reporting obligations, if they have not already done so. The IRS's Offshore Voluntary Disclosure Program (OVDP) is still available.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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