Alternative Investment Industry Technical Update: U.S. Treasury, Cayman Islands Tax Information Authority, FASB, CFTC & SEC

U.S. Treasury:
  • Issued final regulations that relaxed certain reporting obligations for investors in passive foreign investment corporations (PFIC) (T.D. 9806). Please click here to read the Arthur Bell article on these regulations.
  • Issued final regulations that increased the reporting obligations for foreign wholly-owned domestic disregarded entities (T.D. 9796).
  • Accelerated the due date for Form 114 (Report of Foreign Bank and Financial Accounts or “FBAR”) from June 30 (without an extension) to April 15 with a six-month extension to October 15. FinCEN recently announced that the six-month FBAR filing extension would be automatic without taxpayers needing to file an extension request.
Cayman Islands Tax Information Authority (“TIA”):
  • Issued additional guidance on Common Reporting Standards (“CRS”). Under these regulations, all financial institutions are required to report either a nil report or the details of reportable accounts.
  • Issued No. 2016-19, Technical Corrections and Improvements
    • Amendments related to differences between original guidance and the Accounting Standards Codification
    • Guidance clarification and reference corrections
    • Codification simplification through minor structural changes to headings or minor editing of text to improve the usefulness.
  • Issued Annual Staff Reports on Credit Rating Agencies
    • Staff reports demonstrate that compliance and competition continue to increase among the credit rating agencies under SEC oversight as nationally recognized statistical rating organizations (NRSROs).
    • The annual examination report is required by the 2010 Dodd-Frank Act

We welcome your suggestions for future topics that you would like to see included in this Technical Update. Also, for further information regarding these updates and how you may be affected by these changes, please contact your Arthur Bell representative at 855-787-0001 or via email at

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