Skip to content
White CP
White CP
White CP

The Comply Catch-Up – September 2022 Issue 22

Comply Catch-Up September 2022

Key Dates and Reminders

  • On September 22, 2022, the IRS released Rev. Proc. 2022-35 which updates prior guidance and adds Turkey to the current published list of countries with which the United States has in effect a relevant information exchange agreement with respect to information collected under §§ 1.6049-4(b)(5) and 1.6049-8(a) of the Income Tax Regulations relating to payments of deposit interest of $10 or more made by U.S. financial institutions to nonresident alien individuals. Check out Rev. Proc. 2022-35 here

FATCA / CRS Key Dates & Reminders – Select Jurisdictions


  • The IRS Public Key for FATCA will expire soon. The IRS has a new key and will replace the existing key on Friday, October 14, 2022. After October 14, you will need to download the new IRS Public Key from IDES in order to file FATCA Reports. Click here to download the new IRS Public Key. 


  • The annual reporting deadline for Bermuda Reporting Financial Institutions to submit the CRS Compliance Certification Form (the “CRS Compliance Form”) is September 30, 2022. The CRS Compliance Form must be submitted by all Bermuda RFIs and Trustee-Documented Trusts (TDTs). Click here for more information. 

British Virgin Islands 

  • On September 8, 2022, the British Virgin Islands International Tax Authority issued a reminder to all Virgin Islands Financial Institutions (VIFI) that each VIFI is required to provide the name, address, etc. of their principal point of contact for all purposes of compliance and this person will be identified as the “Primary User” within the BVIFARs portal. The Primary User is expected to have a permanent position within the VIFI. A VIFI may appoint an agent to carry out their duties and obligations; however, the agent cannot be appointed as the Primary User and can only be indicated as a Secondary User. To the extent Primary User information needs to be updated, this should be completed by no later than December 31, 2022. Click here for more information. 


  • The Office of the Commissioner for Revenue of Malta issued a notice that it has launched a fact-finding questionnaire to better understand how CRS and FATCA are being implemented in practice. The questionnaire is split into three sections:
    • Due Diligence Procedures 
    • Reporting 
    • Application of CRS and FATCA in Practice 

The questionnaire is intended to assist the Commissioner in identifying difficulties faced by 
Financial Institutions in order to provide the necessary support to FIs to address these issues. The questionnaire will be available for four weeks and is available to access here. 


Comply Updates

Join us at the Sovos Comply and Connect Conference in Washington, D.C. on November 9 – 11. This annual event showcases experts addressing top changes and challenges your business faces in tax withholding and information reporting compliance. Register here. 

We are hiring! Stay tuned for job postings and announcements on new members of the Comply Team. If you or someone you know is interested in a job here at Comply Exchange, please email 

If you would like to schedule a demo and discuss how Comply can help you automate and centralize your information reporting and withholding requirements, contact us at 

More Articles

Definition: When a U.S. person (USP) is required to file...

Definition: A withholding agent may prove that the proper amount...