Whether or not exempt organizations are international in their operations, many are international in their investments, intentionally or unintentionally. As an increasing number of jurisdictions have entered into intergovernmental agreements (IGAs) related to FATCA or agreed to mandate compliance with the OECD common reporting standard (CRS), exempt organizations are being asked to classify themselves in subscription agreements and forms provided to the investment vehicles.
This article considers the classification of three types of exempt organizations under U.S. FATCA, the IGA with the United Kingdom, and CRS. The types of organizations discussed are government entities, pension funds, and traditional charities.
This article is posted with permission.
Paul Carman and Christie Galinski, "Classification of Exempt Organizations under U.S. FATCA, U.K. IGA, and OECD CRS," 29 Journal of International Taxation 38 (August 2018) (Thomson Reuters/Checkpoint).