Offshore clients are putting their funds into U.S. trusts in order to avoid CRS reporting

Various clients are establishing trusts in the U.S. (which has not agreed to exchange information under the Common Reporting Standard) in order to avoid reporting under the CRS.

The motivation of these individuals is the privacy and protection of their families who are resident in the home countries to which CRS reporting will be provided. For countries whose controls on disclosure of financial information are easily subverted, CRS reporting is particularly problematic. Disclosures regarding the foreign assets of these individuals invite extortion, and in some cases kidnapping. Where these concerns are not present, often political risk is.

Neal Armstrong. Summaries of Robert E. Ward, "The Common Reporting Standard Comes to Canada", Tax Management International Journal, 2017, p. 538 under s. 270(1) – reportable jurisdiction person and s. 271(1).