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CLHIA Comments on CRA's Draft CRS Guidance, Self-certification forms & Schema

Release Date: 12/08/2016
Staff Reference: Peggy McFarland

In addition to points noted on our comments on the CRS guidance & the self-certification forms that impact the schema, we have the following additional comments:

1. For the field under Reporting Institution/Document Specification/Document Type Code:

We would like confirmation of these three scenarios:

    1. If the Reporting Institution record is changed but no slip records have changed then R (resend)
    2. If the Reporting Institution record is changed and there are slip record changes then R (resend)
    3. If the Reporting Institution record has not changed but there are changes to slip records then A (amend)
2. ResidenceCountryCode & TINIssueCountry

The XML specs ask for ResidenceCountryCode(tax jurisdiction) as well as TINIssueCountry. Except in the case where no TIN is provided, we would expect these two fields to be the same. The self-certification form does not ask separately for this information. Is there a scenario where the two fields would not be the same?