NFE maintaining assets in non participating jurisdiction
*under contruction *

A simple way to circumvent the CRS is to have a passive NFE maintain its assets in a non participating jurisdiction, such as USA
1. A Passive NFE maintaining its assets in a non participating jurisdiction has no reporting obligations. 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 i the same jurisdiction. The CRS only requires reporting if management and b.o.s are in different jurisdictions.