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The Comply Catch-Up – April 2022 Issue 17

The Comply Catch-Up April 2022

Key Dates and Reminders

  • The Internal Revenue Service (IRS) announced that beginning in mid-April, it will be sending out Notices CP2100 and 2100A to certain financial institutions, businesses or payers. Generally, the IRS sends these notices two times each year to inform payers that they submitted an information return without a Taxpayer Identification Number (TIN), that the information return has an incorrect name, or a combination of both. Click here to read the full article.

  • On April 20, 2022, the IRS posted a final version of Publication 519, U.S. Tax Guide for Aliens, for use in preparing 2021 returns.

  • On April 26, 2022, the Internal Revenue Service (IRS) published Notice 2022-21, which invites the public to recommend items that they should include in the 2022-2023 Priority Guidance Plan.
    • Each year, the Treasury Department’s Office of Tax Policy and the IRS use the priority Guidance Plan to identify and prioritize tax issues that they need to address via regulations, revenue rulings, revenue procedures, notices, and other administrative guidance. Although there is no format for providing recommendation, taxpayers should explain the recommendation, the need for guidance, and if possible, a proposed resolution.
    • Those interested in providing recommendations should do so by Friday, June 3, 2022, electronically via the Federal eRulemaking Portal at . They should type ‘IRS-2022-0007’ in the search field on the homepage to find Notice 2022-21 and submit recommendations.  They can also do so by mailing the recommendation to IRS, Attn: CC:PA:LPD:PR, (Notice 2022-21) Room 5203, P.O. Box 7604, Ben Franklin Station Washington, D.C. 20044.
    • Check out Notice 2022-21 here.

  • As you may remember, the IRS released 2021 revisions of the following forms: W-8BEN, W-8BEN-E, W-8IMY and W-8ECI. If you have not started transitioning to the new form revisions, you should consider doing so as the sunset period will begin to expire starting May 1, 2022.

FATCA / CRS Key Dates & Reminders – Select Jurisdictions

IDES Testing Session

  • The FATCA International Data Exchange Service (IDES) will be open for testing from Monday, June 6, 2022, at 8:00 AM EDT to Friday, July 01, 2022, at 5:00 PM EDT. The test session will only be open to users that completed IDES enrollment by Thursday, June 2, 2022, at 5:00 PM EDT.

  • All testing sessions will be announced on the IDES Testing Schedule web page. For more information on testing, sample files, and FAQs, visit the IDES Resources webpage.

Antigua and Barbuda

  • The Antigua and Barbuda Inland Revenue Department published its own Common Reporting Standard (CRS) Compliance Form that must be completed by all registered Antigua and Barbuda Reporting Financial Institutions (FIs). These Reporting FIs must submit the new CRS Compliance Form by October 30, 2022, for the 2021 reporting period. The same date will apply annually for future reporting periods. Check out the Antigua and Barbuda Compliance Form Guide.

British Virgin Islands

  • On April 1, 2022, the International Tax Authority (ITA) of the British Virgin Islands published an updated List of Participating Jurisdictions for the Common Reporting Standard.


  • As a reminder, Canadian Financial Institutions (FIs) must report the details of their 2021 FATCA and CRS accounts to the Canadian Revenue Authority by May 2, 2022.

Cayman Islands

  • On March 31, 2022, the Cayman Tax Information Authority (TIA) published the Enforcement Guidelines in respect of the Common Reporting Standard (CRS) and Economic Substance (ES), which set forth the principles and processes for the TIA to enforce action under their respective frameworks. Of note are the ‘Description of Offences’ and applicable penalties for both an organization and individual offender. Click here to read the full article.


  • On March 31, 2022, the States of Guernsey Revenue Service published Common Reporting Standard (CRS) and Foreign Account Tax Compliance Act (FATCA) Compliance Information Notice 2. Among a number of updates and links to guidance, the Compliance Information Notice identified a few key areas that require attention. Those key areas can be found here.

 You can review the Compliance Information Notice 2 here.

  • On April 13, 2022, the States of Guernsey Revenue Service issued Bulletin 2022/3. The Bulletin reminds all Reporting Guernsey Financial Institutions (“RGFIs”) that the FATCA and CRS reporting deadlines are June 30, 2022.



  • On April 4, 2022, the Tax Administration of Luxembourg (ACD) updated their FAQs for the Common Reporting Standard.


  • On April 11, 2022, the OECD published updated information on Tax Identification Numbers (TINs) for Colombia.


  • On April 25, 2022, the Inland Revenue Authority of Singapore (IRAS) published an update reminding all Reporting SGFIs to submit their FATCA and CRS returns for calendar year 2021 by May 31, 2022. Enforcement actions will be taken against Reporting SGFIs that do not submit their FATCA and CRS returns on time. Further, new enforcement actions were added to the FATCA Filing Webpage stating that Reporting SGFIs may see enforcement actions with penalties of up to $5,000 for late or non-filing of FATCA returns. IRAS has stated that five months after the end of the reporting period is a reasonable deadline, and as such, they will not grant any extensions unless the Reporting SGFI is newly registered and has circumstances that fall within a specified list of acceptable reasons that include:
    • Newly registered Reporting SGFIs with a first return submission may receive one month extension.
    • Reporting SGFIs that have a breakdown of internet technology system or change of internet technology system or software may receive two weeks extension.
    • Reporting SGFIs that have key personnel handling FATCA filing that are on an unexpected long medical leave may receive two weeks extension.

IRAS will not grant extensions where Reporting SGFIs claim they do not have enough manpower to handle FATCA returns, that key personnel are located overseas or that they resigned without proper handover, or that new staff does not know how to handle FATCA matters.

United Kingdom

  • On April 25, 2022, the International Tax Compliance (Amendment) Regulations 2022 were made and then laid before the House of Commons on April 26, 2022. They will enter into force on May 18, 2022. These rules extend the UK legislation implementing its automatic exchange of information agreements relating to the Common Reporting Standard (CRS), specifically to agreements entered into as of April 20, 2022.

United States

  • On April 1, 2022, the Internal Revenue Service (IRS) published a Memorandum for all Large Business and International (LB&I) employees that reissues Interim Guidance Memorandum LB&I-04-0120-0002 dated April 7, 2020. The 2020 Memorandum provides guidance for procedures for FATCA Certification Event of Default Notices. The guidance in this new April 2022 memorandum remains unchanged. Further, these procedures will be incorporated into new IRM 4.65.3, FATCA Foreign Financial Institution (FFI) Operational Procedures and Compliance, no later than October 22, 2023.
  • On April 7, 2022, Internal Revenue Service (IRS) Commissioner Charles P. Rettig testified on agency operations and the President’s 2023 budget request before the Senate Finance Committee. Click here to read the full article.
  • On April 12, 2022, the Treasury Inspector General (TIGTA) published an April 7, 2022, Report Number 2022-30-019, titled ‘Additional Actions Are Needed to Address Non-Filing and Non-Reporting Compliance Under the Foreign Account Tax Compliance Act (FATCA).’ TIGTA conducted this audit to evaluate efforts by the Internal Revenue Service (IRS) to use information collected under FATCA to improve taxpayer compliance. Click here to read the full article.

Comply Updates

Comply Exchange will be sponsoring the 2022 Tax Reporting and Withholding Conference hosted by The Tax Reporting Group on May 2 – May 4. If you have not already signed up, you can register and find additional information here.

The Comply Wallet is now live and available for download from the Apple App Store and Google Play Store. The Comply Wallet is our new intelligent Document Wallet aimed to increase accessibility and mobility of user’s who must submit the same complex tax documents to multiple recipients. With our integrated mForms application, you can submit Forms W-8, W-9 and self-certifications.


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