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FATCA/CRS Compliance

International Client Tax Reporting

In recent years many countries, including most Caribbean jurisdictions, have signed treaties and implemented agreements in order to assist each other with their common pursuit of global tax transparency. As these agreements are implemented, CIBC FirstCaribbean is obliged to collect additional information from its clients in order to confirm tax residency details for its account holders. Based on tax residency and or US citizenship, CIBC FirstCaribbean has a legal obligation to report customers financial account information to the relevant local, regional or extra-regional tax authority.

Customer Impact [ ]

CIBC FirstCaribbean is required to collect information and documentation from individual and entity customers to establish their tax residency. For most individual clients this is usually the jurisdiction where they reside and pay taxes. US Citizens, however, are also treated as US residents for tax purposes, regardless of their country of residence. If you are unsure about your tax residency or US Status, you should seek advice from a professional tax adviser or the relevant tax authority. CIBC FirstCaribbean does not provide tax advice.

Foreign Account Tax Compliance Act (FATCA) [ ]

FATCA was enacted in 2010 by the US Congress to target non-compliance by U.S. taxpayers using foreign accounts. FATCA requires foreign financial institutions (FFIs) to report to the IRS information about financial accounts held by U.S. taxpayers, or by foreign entities in which U.S. taxpayers hold a substantial ownership interest. In most Caribbean jurisdictions, FATCA is implemented locally through an Intergovernmental Agreement (IGA). In jurisdictions where no IGA is in effect, CIBC FirstCaribbean has entered into an FFI agreement directly with the US IRS.Learn more about FATCA from the US IRS webiste

Common Reporting Standard (CRS) [ ]

The Organization for Economic Cooperation and Development (OECD) developed the Common Reporting Standard (CRS) in response to the G20 request for jurisdictions to obtain information from financial institutions and to automatically exchange that information with other jurisdictions on an annual basis. The CRS, based on FATCA, is being adopted by a large and growing number of countries including most Caribbean jurisdictions. It requires CIBC FirstCaribbean to collect information from individuals and entities to establish their tax residency. Depending on the account holder’s tax residency, the bank may also be required to report financial account details to the relevant tax authorities.Learn more about CRS on the OECD website.


The United Kingdom has signed agreements similar to FATCA with the governments of its Overseas Territories (OT) including; Anguilla, British Virgin Islands, Cayman Islands and Turks and Caicos Islands. CIBC FirstCaribbean is required under these agreements to submit financial account details for all UK reportable persons that hold accounts in these jurisdictions. Learn more about CDOT on the HMRC webiste

Self-Certification Forms [ ]

Further Information or Questions? If you are unsure what this means for you or should you have further questions and require additional information please contact your relationship manager or contact CIBC FirstCaribbean directly.