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Podcast: Offshore Tax with HTJ.tax
Episode: Why Custodial Institutions Are Not Look-Through Entities
Description: Automatic Exchange of Information (AEOI) under CRS/FATCA is highly structured and tiered. It is designed to allocate reporting once—not duplicate it. Yet a frequent error is to apply Passive NFE look-through rules to Financial Institutions (FIs), particularly Custodial Institutions (CIs). In this episode, we explain why that approach is incorrect.🔎 What You’ll Learn1️⃣ The CRS/FATCA Hierarchy (Why Duplication Is Prohibited)CRS/FATCA establishes a strict reporting hierarchy:Financial Institutions are Reporting FIs, not Reportable Persons.The system intentionally avoids duplicate reporting by multiple FIs on the same interest.Misr...