Manage assets in non participating jurisdiction

A simple way to circumvent the CRS is to have a an maintain its assets in a non participating jurisdiction, even if managed by a CRS based wealth manager
1. An entity maintains its assets in a non participating jurisdiction The CRS amendment will make such entities reportable investment entities. Making the management of these entities report will be ineffective as the manager and beneficial owner will be in the same jurisdiction. The CRS only requires reporting if management and b.o.s are in different jurisdictions.