Declaring your Caribbean bank accounts

A few months back, I got a panicky email from my aunt, who lives in the US.  She was told that she might be in trouble because of her bank accounts on Trinidad’s sunny island, which she and my uncle had not previously declared to the IRS.

I immediately arranged a Skype call with her and helped ease her mind.  She had nothing to worry about as she was properly declaring the interest, and the accounts were below the reporting threshold.

Unfortunately, many first and second-generation immigrants are blissfully unaware of their responsibility to report their foreign financial assets.  Much of the focus has been on Switzerland, but few very well known Caribbean banks are under investigation or are cooperating with US government investigations.  First Caribbean, Stanford, and Butterfield are well known retail banks in the Caribbean region.  I myself once had an account with First Caribbean.

The complete list is as follows-

  1. UBS AG
  2. Credit Suisse AG, Credit Suisse Fides, and Clariden Leu Ltd.
  3. Wegelin & Co.
  4. Liechtensteinische Landesbank AG
  5. Zurcher Kantonalbank
  6. Swisspartners
  7. CIBC FirstCaribbean International Bank Limited, its predecessors, subsidiaries, and affiliates
  8. Stanford International Bank, Ltd., Stanford Group Company, and Stanford Trust Company, Ltd.
  9. HSBC India
  10. The Bank of N.T. Butterfield & Son Limited (also known as Butterfield Bank and Bank of Butterfield).

Unfortunately, these banks’ customers are no longer eligible for the new OVDP program.

Changes to the IRS Disclosure Programs

I am also concerned about the Trinidad and Tobago Unit Trust Cooperation, which, according to the IRS website, has not yet registered as an FFI for FATCA.  Very strange given that it offers US funds to Caribbean nationals.  Some of their funds may actually be considered a PFIC (a particularly nasty penalty like treatment that many US persons face with their foreign mutual funds), and it is a well-known fact that they have many US persons on their books.  The sluggishness with which certain Caribbean financial institutions are moving is cause for grave concern.

In the meantime, US taxpayers face a race against the clock as the above list grows, and it is just a matter of time before their foreign financial institution reports them.  The bottom line is that it is time to consult a US qualified tax professional for advice on coming forward.

Table of Contents: Declaring your Caribbean bank accounts

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