How Gen II Streamlines FATCA & CRS Reporting for Investment Funds

Authored by: Kevin Zeman, Principal, Tax
Updated on: April 24, 2024

What is FATCA / CRS?

Both FATCA/CRS are pivotal regulatory and reporting frameworks designed to combat offshore tax evasion. FATCA and CRS have far-reaching impacts on the investment fund industry, requiring investment funds to enhance onboarding processes, collect additional information on investors, and develop reporting processes and procedures.

In United States law, the Foreign Account Tax Compliance Act (FATCA), which came into effect on July 1, 2014, is intended to reduce the levels of tax avoidance by U.S. citizens and entities through foreign financial institutions (FFIs).

Globally, the Organization for Economic Cooperation and Development created the Common Reporting Standard (CRS) to facilitate the automatic exchange of information.

The overarching goal of both the FATCA and CRS frameworks is to give governments a more transparent view of the financial assets their citizens hold in foreign accounts. Though their goals are similar, the FATCA and CRS frameworks have many important differences.

Who Must File?

FATCA and CRS reporting obligations apply to Financial Institutions, a term which is broadly defined and generally captures entities' investment management functions, as well as investment funds themselves.

To ensure proper compliance with the FATCA and CRS legislation, it is imperative that investment funds and investment managers are properly classified and duly registered for FATCA purposes with the IRS, the Department for International Tax Cooperation in the Cayman Islands, or in other local jurisdictions.

Compliance with FATCA and CRS requires meticulous record-keeping, form validation, and ongoing monitoring of investment accounts and investor demographic information. Here, we delve into the essential services offered in Gen II Tax compared to other providers in the industry.

Why Choose Gen II Tax Services?

Gen II Tax offers a comprehensive suite of services to ensure FATCA and CRS compliance. They handle everything from initial data collection and form validation to ongoing monitoring and reporting. Other providers may offer similar services but might lack the depth and integration that Gen II Tax provides.


Tax Services

Other Providers

Gen II Tax

FACTA & CRS Processing

Fully maintain relevant Fund investor/entity information required by FATCA and CRS regulations

Case by Case


Perform the required form validations and perform jurisdictional indicia checks required under FATCA and CRS for each investor

Case by Case

Collection of appropriate IRS tax forms (Form of W-8 or W-9) and/or withholding certificates and tax residency self-certifications

PBC Reliance

Collecting the appropriate self-certification forms for investors, including identified Controlling Persons and supporting documentation.

PBC Reliance

Reviewing the forms for completeness, accuracy, and validity to determine sufficiency for FATCA and CRS classifications


Verifying an Investor’s GIIN against the IRS FFI List for the purposes of the US IGA

Case by Case

Ad-hoc reporting for relevant Fund investor/entity information required by FATCA and CRS regulations

Out of Scope

Ongoing FACTA & CRS Monitoring

Monitoring tax forms for expiration, as applicable and, where required



Request new forms from Investors within a reasonable time before such expiration

PBC Reliance

Monitoring for any additional information received from the Fund, or an investor, and updating the investor’s CRS classifications


Ongoing validation of Investors’ GIINs against the IRS FFI list as necessary and monitoring for any additional information received from the Fund, or an investor, and updating the investor’s FATCA statuses

Case by Case

Additional Services

U.S. Federal Tax Withholding Assistance

Not Included


Rate Valuation

Not Included

Investor IMY Package Creation and Maintenance

Not Included

Published on: April 24, 2024

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