How to restructure trusts out of scope
* Under Contruction *


How to restructure trusts out of scope
1. Early adopter trusts
  1. Ensure trust remains an investment entity by appointing FI as investment
  2. Change trustee to individual settlor.
    • Previous trustee won't report as investment entity not closed.
    • Previous trustee won't report on himself as trustee surrendering Equity Interest because trustee is in same jurisdiction as himself.
      (Assuming there are no other jurisdiction trustees)
    • It's the settlor-trustee at end of year or upon closure that has reporting obligations.
  3. Settlor-Trustee closes trust.
    (Not reportable by individual trustee as he is in same jurisdiction as settlor, which is himslef. This is a structural weakness of CRS where Investment Entities do not report on themeselves if the management is in same jurisdiction as Euity Interest beneficial owners)
2. Late adapoter trusts
  1. Ensure trust remains an investment entity by appointing FI as investment
  2. Change trustee to late adopter trustee (individual or corporate).
    • Previous trustee won't report as investment entity not closed.
    • Previous trustee won't report on himself as trustee surrendering Equity Interest because trustee is in same jurisdiction as himself.
      (Assuming there are no other jurisdiction trustees)
    • It's the trustee at end of year or upon closure that has reporting obligations.
  3. Trustee closes trust.
    (Not reportable by late adopter trustee)