AEOI Reporting (IRS) Filer Category

Good Morning,

Has anyone else experienced issues with submissions of AEOI returns and IRS now wanting a ‘filer category’ completed?

The AEOI returns that we complete in respect of a particular trust are solely because the trust in question is classed as a financial institution and cash distributions have been paid to reportable persons in the year.

The trust is classified as a reporting Financial Institution because more than 50% of its income is from investing, reinvesting, or trading in financial assets, and another Financial Institution has discretionary authority to manage these assets wholly or in part. The trust is regarded as being managed by a Financial Institution because the trustees have appointed a Financial Institution, such as a discretionary fund manager, to manage the trust’s assets.

HMRC have advised via the telephone to complete the filer category as ‘Registered Deemed Compliant Foreign Financial Institution’. However, they will not commit to this in writing.

Does anyone else have experience of this or can provide any advice?

Thank you,