Course Outline

Introduction to CRS and Global Tax Transparency for Government

  • History and purpose of the Common Reporting Standard (CRS) and Automatic Exchange of Information (AEOI)
  • Entities required to report: Reporting Financial Institutions and the scope of reportable accounts
  • How CRS relates to FATCA, including areas where their requirements overlap and differ

Legal & Regulatory Framework for Government

  • Jurisdictional implementation models and legal instruments (Multilateral Competent Authority Agreement (MCAA), domestic legislation)
  • Recent consolidated texts and amendments impacting due diligence and scope
  • Compliance obligations, timelines, and penalties for non-compliance in the public sector

Due Diligence Fundamentals: Identifying Tax Residency for Government

  • Required documentation: self-certifications and reliable documentary evidence for government purposes
  • Indicia search procedures for new and pre-existing accounts within government systems
  • A comprehensive approach to due diligence, including the use of AML/KYC information to determine tax residence for government entities

Operationalizing CRS: Onboarding, Data Capture, and Systems for Government

  • Integrating CRS checks into client onboarding and periodic review workflows for government agencies
  • Data elements required for reporting and practical approaches to data quality and retention in a government context
  • Using automation and vendor tools versus manual processes; considerations for service providers supporting government operations

FATCA-like Requirements and Comparative Best Practices for Government

  • Key commonalities with FATCA (classification, reporting mechanics, treatment of entities and beneficiaries) in the context of government compliance
  • Differences to plan for (scope, bilateral vs. multilateral implementation, jurisdictional variance) within government frameworks
  • Practical mapping exercises: converting FATCA controls into CRS-compliant processes for government agencies

Reporting, Exchange Mechanisms, and Audit Readiness for Government

  • Formats and transmission channels for CRS reports; jurisdictional submission requirements for government entities
  • Preparing for audits and regulator reviews: documentation, traceability, and evidence of due diligence in a government setting
  • Sample reporting workflows and reconciliation checks tailored for government operations

Risk Management, Governance, and Internal Controls for Government

  • Designing governance frameworks, policies, and segregation of duties for CRS compliance within government agencies
  • Training, quality assurance, and exception handling for complex/entity accounts in the public sector
  • Remediation pathways and multi-jurisdiction coordination for legacy accounts within government systems

Practical Labs and Case Studies for Government

  • Lab: Review and validate a set of sample account files and self-certifications; determine reportability for government purposes
  • Lab: Configure a simple data-extraction and reporting checklist; produce a mock CRS XML extract suitable for government submission
  • Case study: Handling complex entity structures, trusts, and controlling persons under CRS rules in the context of government operations

Summary and Next Steps for Government

Requirements

  • An understanding of financial services or compliance functions for government
  • Familiarity with basic tax concepts and customer onboarding processes
  • Experience with AML/KYC procedures is beneficial but not mandatory

Audience

  • Compliance officers and legal teams within government agencies
  • Onboarding, KYC, and client due diligence staff in public sector organizations
  • Tax reporting and operations teams in financial institutions serving the public sector
 14 Hours

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