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The Comply Catch-Up – March 2021 Issue 4

The Comply Catch-Up March 2021

Comply Updates


  • Comply is excited to announce the launch of their latest innovation, the Comply Exchange mobile E-Forms application. Available to fully integrate within account opening processes and compatible with both the App Store and Play Store, account holders can securely submit tax documentation with ease and on the go, whilst strictly following IRS guidelines and directives for compliant e-sign Forms W-8 and W-9 
  • If the mobile world is your way forward, we are already working on our next innovation and taking the account holder experience to the next level – this one is super exciting so either contact us for a quick chat or keep an eye out for further updates!  
  • Comply is excited to partner with Sovos at the upcoming Crypto Tax Workshop, which will be held on April 20 from 1pm – 5pm EST. The best part? You can attend for free! Register here so you don’t miss out on learning more about navigating increased Crypto Tax & Compliance obligations in 2021. 
  • In case you missed it, Comply will be sponsoring the 2021 Tax Reporting & Withholding Virtual Conference. The conference will be held on Tuesday, April 27 – Wednesday, April 28, 2021. If you haven’t already, register here. 



Form 1099 Key Dates & Reminders

  • As a reminder, certain Forms 1099 are due to be filed with the IRS by March 31, 2021, if filing electronically. This includes, but is not limited to, Forms 1099-DIV, 1099-INT, 1099-MISC, 1099-OID, and 1099-R. For additional information regarding 1099 due dates, refer to the General Instructions for Certain Information Returns or instructions for applicable return.

Form 1042/1042-S Key Dates & Reminders

  • Forms 1042-S and 1042 were due on March 15, 2021, unless an extension of time to file to the IRS (Form 8809 for 1042-S and Form 7004 for 1042) and extension to furnish recipient statements (Letter to IRS) were filed by the deadline. 
    • Form 1042-S Extensions: Allows for 30-day extension of time from March 15, 2021.  
    • Form 1042: Allows 6-month extension of time from March 15, 2021.  

Form 8804/8805 Key Dates & Reminders

  • Forms 8804 and 8805 are generally due on or before the 15th day of the 3rd month following the close of the partnership’s tax year. For partnerships that keep their records and books of account outside the United States and Puerto Rico, the due date is the 15th day of the 6th month following the close of the partnership’s tax year.  
  • If more time is needed to file, request an extension of time by filing Form 7004. Note: Filing Form 7004 doesn’t extend the time for payment of tax.

FATCA / CRS Key Dates & Reminders – Select Jurisdictions



  • The Bahamas Competent Authority published key dates on the AEOI portal availability for TY2020 FATCA and CRS registration and submissions. The Bahamas Competent Authority AEOI Portal will open on Monday, July 19, 2021 at 9am EDT for registrations and submissions, and will close on Friday, August 27, 2021 at 5pm EDT.  

Cayman Islands


  • The Cayman Islands’ Department for International Tax Cooperation (DITC) published revised regulation documents on their CRS and FATCA Legislation & Resources sections of the website: 
  • On March 1, 2021, the Cayman Islands’ DITC also published an updated list of CRS reportable jurisdictions. Albania and New Caledonia have been added for reports due in 2021 onwards. See full list of Cayman Islands CRS reportable jurisdictions here.  



  • Form 8966 FATCA Report is required to be filed for the 2020 calendar year on or before March 31, 2021.  
    • An automatic 90-day extension of time to file Form 8966 may be requested by filing Form 8809-I Application for Extension of Time to File FATCA Form 8966. No extension of time to file is permitted for Form 8966 filed by a Reporting Model 2 FFI to report a non-consenting U.S. account. A Reporting Model 2 FFI should refer to the applicable Model 2 IGA for the due dates for those filings.  
  • You are required to file Form 8966 if you are a PFFI, U.S. branch of an FFI not treated as a U.S. person, RDCFFI, Related entity or branch described in an applicable Model 2 IGA, Reporting Model 2 FFI, Qualified Intermediary, Withholding Foreign Partnership, Withholding Foreign Trust, Direct Reporting NFFE, Sponsoring Entity, or Trustee-Documented Trust. See instructions for Form 8966 for further details on filing requirements: 2020 Instructions for Form 8966 ( 
  • Note: Form 8966 is not used to report any tax withheld under Chapter 4 to the IRS. A withholding agent may, in addition to Form 8966, also have to file Form 1042 and 1042-S to report any tax withheld under Chapter 4.



  • As a reminder, CRS XML Schema Version 2.0 and CRS User Guide Version 3.0 are applicable for all exchanges from February 1, 2021 forward. Both the Schema and User Guide can be accessed on the OECD website.


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