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SPV Custodial Structures and CRS Compliance

SPV Custodial Structures and CRS ComplianceThe analysis of SPV custodial structures is not purely theoretical. In practice, classification questions can become highly technical and may require detailed documentary evidence, legal analysis, and engagement with regulated financial institutions.My experience has involved several of these issues directly.🏦 1️⃣ The 20% Custodial Institution TestA key CRS classification question is whether an entity satisfies the income test relevant to Custodial Institution status.In one case, a BVI bank instructed me to conduct a formal review of whether the 20%…

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