The Foreign Account Tax Compliance Act (FATCA) is a United States law that requires certain financial institutions and other non-financial entities outside the US to report information about financial accounts held by US persons.
The Common Reporting Standard (CRS) is a global standard developed by the Organisation for Economic Co-operation and Development (OECD) for the automatic exchange of financial account information between tax authorities. Financial institutions in participating jurisdictions report accounts held by tax residents of other participating jurisdictions.
Both regimes are reported annually to your local tax authority: the Australian Taxation Office (ATO) in Australia, or Inland Revenue (IRD) in New Zealand.
Caruso generates everything you need in one download: the FATCA & CRS Tax Pack. For each regime, the Tax Pack gives you an XML file that can be lodged directly with your tax authority, and an Excel data file showing exactly what the XML contains, which you can use to review and reconcile your data before lodging.
Registration
If your organisation is required to report under FATCA, you must first register with the US Internal Revenue Service (IRS) using the FATCA Registration Website. Once approved, the IRS will provide a Global Intermediary Identification Number (GIIN), which must be included in all FATCA reports. You enter the GIIN once against your fund in Caruso (see Fund configuration below). CRS has no equivalent registration number. In Australia, CRS reports are lodged through ATO Online Services. In New Zealand, register for CRS reporting through myIR before filing your first disclosure.
Fund configuration
The Tax Pack is built from your fund's tax reporting configuration and your investor records. This configuration must be completed before any reporting is possible, so set it up first for every fund you report on.
Note: the fund's configuration never includes or excludes the fund from reporting — every fund with complete configuration generates both the FATCA and CRS reports. It is investors who are included or excluded, based on their own classifications and tax residencies (see Who is reported below).
In the navigation pane, open your fund and go to the Tax Reporting tab. The tab has three sections:
Regulatory Lodgement
Required for all funds, for both FATCA and CRS. This identifies the entity lodging the report to your tax authority:
Entity name
Tax identification number (for New Zealand funds, the IRD number; Australian funds enter their ABN in the AU Tax Reporting section instead)
Contact name, phone, and email
Entity address
AU Tax Reporting
Australian funds also complete this section, including the Entity ABN.
FATCA & CRS
Required before generating a FATCA report:
Fund GIIN: the Global Intermediary Identification Number issued by the IRS on registration. Required for FATCA generation, unless the fund's sponsor is a FATCA609 trustee (a trustee-documented trust).
FATCA filer category: your fund's filer classification, reported as the filer category in the FATCA file. Fund filer categories are codes FATCA601 to FATCA606, FATCA610, and FATCA611; sponsor filer categories are FATCA607 to FATCA609. Required for FATCA generation unless a sponsored arrangement is configured — sponsored funds report under the sponsor's filer category instead. The filer category describes your fund to the tax authority; it does not determine which investors are included.
Sponsored arrangement: if your fund reports through a sponsoring entity, switch this on and complete the sponsor's name, GIIN, tax identification number and country, address, and filer category.
Intermediary arrangement: if an intermediary is involved, switch this on and complete the intermediary's name, TIN and country, and address.
Note: CRS does not require any additional fund fields beyond the Regulatory Lodgement details.
Investor data
Investor-level data comes from the tax details captured on each investing entity and its related parties: tax residencies, taxpayer identification numbers (TINs), FATCA and CRS classifications, dates of birth, and addresses.
Important: the reports only assess the related parties recorded directly against the investing entity. If an owner or controlling person's interest runs through an intermediate entity, record that individual directly as a related party of the investing entity so they can be reported — see Who is reported below.
How to download the FATCA & CRS Tax Pack
In the navigation pane, select Reports.
Select the FATCA & CRS Tax Pack.
Select the reporting year. The year you select is the year the reporting period ends. Reporting periods are based on the fund's country; once you select a fund, the exact period displays on screen (see Key dates below).
Select the fund. Each download covers one fund. If you report for several funds, repeat the download per fund.
Click Generate. Generation runs in the background — the operations panel opens so you can follow progress, and larger funds may take a few minutes.
When the operation completes, download the Tax Pack (a ZIP file) from it.
If any required fund configuration is missing, generation stops and tells you which fields to complete.
Who is reported
Caruso applies the regulators' inclusion rules automatically when you generate, using your investor records. The same mechanics drive both regimes:
The reporting period sets the frame. Every investing entity that held units in the fund at any point during the reporting period is assessed against each regime's rules. Account balances are taken at the period end date, and payments are those made during the period. An investor who fully redeemed during the period is still reported, marked as a closed account with a zero balance.
Investing entities are the accounts. Each reportable investing entity becomes one account in that regime's report (joint holders are reported individually — see Joint individual accounts under Understanding the outputs).
Individuals are assessed on their tax residencies (and, for FATCA, US-person self-certification).
Organisations are assessed on their FATCA or CRS classification and, for CRS, their tax residencies.
Related parties become substantial owners (FATCA) or controlling persons (CRS). When an organisation's classification calls for its owners to be reported, Caruso reports each individual related party recorded directly against that investing entity who meets the regime's residency test. Related parties that are themselves organisations are not expanded — individuals recorded underneath them are not assessed, so record such individuals directly on the investing entity.
Not every reportable organisation lists owners. For example, a CRS report for an organisation classified as an Active NFE that is tax resident in a reportable jurisdiction reports the entity as the account holder with no controlling persons — that is the format the regulator requires, not missing data.
Note: investor details such as tax residency, classification, name, and address are reported as they stand at the time you generate. Generate your reports soon after the period ends so the details reflect the reporting period as closely as possible.
Included in the FATCA report
Inclusion in the FATCA report is driven by US indicia for individuals and by the FATCA classification for organisations:
Individuals (including joint holders) who are US tax residents or have certified as US persons.
Organisations classified as a Specified US Person, Non-Participating FFI, Direct Reporting NFFE, or Owner Documented FFI — these classifications are reportable in their own right, regardless of the organisation's tax residencies or related parties.
Organisations classified as a Passive NFFE — reportable only when at least one directly recorded individual related party is a US tax resident or certified US person. Those individuals are reported as substantial owners.
Substantial owners are reported for Passive NFFE, Owner Documented FFI, and Direct Reporting NFFE organisations. Sponsored Direct Reporting NFFEs are reported through their sponsoring entity's own lodgement, not the fund's.
Included in the CRS report
The CRS report covers account holders tax resident in a CRS reportable jurisdiction other than the fund's own country. The United States is excluded because it does not participate in the CRS — the US exchanges account information under FATCA instead, so US tax residents are covered by the FATCA report:
Individuals (including joint holders) with a tax residency in a reportable jurisdiction. An individual resident in more than one reportable jurisdiction is reported once per jurisdiction.
Organisations with their own tax residency in a reportable jurisdiction, according to their CRS classification — an organisation is reportable in its own right on its own residency, whether or not any related party is reportable.
Organisations classified as a Passive NFE are additionally reportable when at least one directly recorded individual related party is resident in a reportable jurisdiction — those individuals are reported as controlling persons, with their controlling person type derived from the relationship recorded on the related party.
Excluded from both FATCA and CRS
FATCA — organisations classified as Active NFFE, Participating FFI, Deemed Compliant FFI, or Exempt Beneficial Owner are not reportable. An organisation whose FATCA classification is missing or set to Other is not reported, and is flagged in the generation notes for your review.
CRS — organisations classified as a government entity, international organisation, central bank, publicly traded corporation, or a related entity of a publicly traded corporation are not reportable.
Both — investors who only hold tax residency in the fund's own country; investors who fully redeemed before the reporting period started; and individuals recorded underneath organisational related parties (record them directly on the investing entity to report them).
What the Tax Pack includes
One ZIP covers both regimes. For each of FATCA and CRS it contains:
The XML file
The lodgement file, built to the reporting schema your tax authority requires (the IRS FATCA XML schema for FATCA; the OECD CRS schema for CRS). This is the file you lodge with the ATO or IRD. You do not need to edit it.
The Excel data file
A spreadsheet showing the same information as the XML in a readable format: your fund and lodging entity details, the reporting period and report references, then one row per reportable account holder with their identity details, tax residencies and TINs, address, account balance and payments, and — for organisation accounts — the substantial owner (FATCA) or controlling person (CRS) reported on that row.
Because the file is one row per reported person, an investing entity's details repeat across rows where more than one person is reported for the same account: a joint account produces one row per reportable joint holder, and an organisation with several substantial owners or controlling persons produces one row per owner, each repeating the account's details.
Use the data file to review and reconcile what will be lodged before you lodge it.
The generation notes file
Included in the Tax Pack only when something needs your review — one file per regime. Each row identifies the affected investing entity (with a direct link to it in Caruso), the specific record the issue sits on where it is not the entity itself (such as a joint holder or a related party, also linked), and the reason it was flagged.
The notes flag two kinds of issue:
Records excluded from the report — for FATCA, an investing entity whose FATCA classification is missing or set to Other is not reported, and appears in the notes so you can classify it and generate again.
Records reported with incomplete data — the report still includes the account, but a value the regulator expects could not be populated. Reasons include:
missing identity details — first name, last name, organisation name, or a date of birth that is missing or invalid
missing tax details — tax residence country not provided (or not a recognised country), or a taxpayer identification number not provided
missing address details — address country or city not provided
missing account values — account number, account balance value, or balance currency not provided
a CRS classification set to Other — the organisation is still reported, but the classification needs manual review
more tax residencies than the data file's columns can show — the additional residencies are still reported in the XML
To resolve a note, open the linked record, complete or correct the flagged details, and generate the Tax Pack again. Generation is never blocked by notes — the reports still produce — but review every note before lodging, as flagged records are either missing from the report or reported with gaps.
Nil reports
If the fund has no reportable accounts for the period, Caruso still produces valid files: the XML is a nil report in the regulator's required format, and the data file shows the report details with no account rows. In Australia a nil report can be lodged the same way as any other report. In New Zealand, nil reports are not required by the IRD.
Understanding the outputs
Every value in the Tax Pack is built from data you can see in Caruso, so you can reconcile the files against your records before lodging.
Field | How it is derived |
Account holder type |
|
Joint individual accounts |
|
Account closed |
|
Undocumented account (CRS only) |
|
Account balance |
|
Payments (Other payment) |
|
Effective dates at a glance
Value | Taken as at |
Who is included | Held units, or was paid, at any point during the reporting period |
Account balance | Period end date |
Account closed | Zero units at the period end date |
Distributions and redemption proceeds | Distributions where the 'Paid To' date is within the period |
Names, addresses, residencies, TINs, classifications | As recorded at the time you generate |
Keeping records of what you lodge
Each download is generated fresh from current data, so a later re-download is a new report rather than a copy of what you lodged. To keep records:
Re-download recent packs from Tools → Operations — every generation is kept on its operation, so you can retrieve a pack you generated earlier.
Keep a permanent record of what you lodged by uploading the Tax Pack ZIP to the fund's documents with admin-only visibility. This preserves the exact files you submitted to the tax authority alongside the fund's other records.
Lodging your reports in Australia
The ATO's end submission format is XML for both regimes, and the Caruso Tax Pack gives you that file directly. Lodge each XML file through ATO Online Services using the File Transfer facility:
Log in to Online services for business (or Online services for agents).
Select Lodge file, then choose Test to validate your file first. The ATO accepts the same file for testing and lodgement, so you can check for errors before lodging.
Once the validation report is clean, lodge the file. Lodge the FATCA and CRS files separately.
The ATO also provides Small Reporter Tools (SRTs) — Excel files that smaller reporters populate manually and which then generate the XML in the prescribed format (up to 50 individual and 50 organisational reportable accounts for FATCA; fewer than 50 reportable accounts for CRS). Because Caruso already generates the XML, you no longer need the SRTs — simply review your data using the Caruso data file and lodge the Caruso XML. If you do prefer the SRT channel, you can use the Caruso data file as the source for populating it; enter values manually rather than pasting, as the ATO advises copy-paste can corrupt the tools.
Key dates (Australia — FATCA and CRS)
Reporting period | 1 January to 31 December of the selected reporting year |
Due date | Lodge with the ATO by 31 July of the following year |
Extensions |
Lodging your reports in New Zealand
The IRD's disclosure formats all resolve to the same reported data, and the Caruso Tax Pack gives you the XML directly. Through myIR you can:
Upload the XML: lodge the Caruso XML file directly in myIR. This is the simplest option — myIR validates the file at upload and will not accept a file containing errors, so a successful upload confirms the file passed the IRD's checks.
Use the IRD's Excel template: an Excel file (up to 1,000 records) that is populated manually and generates the disclosure in the prescribed format when uploaded. Because Caruso already generates the XML, you no longer need the template — but if you prefer it, use the Caruso data file as your source, and always download the current template version from myIR.
Use the online form: for small numbers of accounts, enter the details manually in myIR using the data file as your source.
Key dates (New Zealand — FATCA and CRS)
Reporting period | 1 April to 31 March, ending in the selected reporting year |
Due date | Lodge with the IRD by 30 June of the selected reporting year |
Extensions | May be available by request to the IRD |
Reporting assumptions
Caruso applies a small number of documented assumptions when building these reports. Trustees and compliance officers should review these before lodging:
Substantial owners and controlling persons are identified by tax residency rather than ownership percentage, as Caruso does not capture ownership thresholds. This over-reports rather than under-reports.
Only individuals recorded directly as related parties of the investing entity are assessed as substantial owners or controlling persons; individuals held under an organisational related party are not reported.
Organisations that qualify as both a reportable person and a passive entity with reportable controlling persons are reported once, as a passive entity with controlling persons.
Missing US TINs are reported using the IRS's placeholder codes, always paired with the individual's date of birth if available.
Controlling person types are derived from the relationship recorded on each related party (for example, trustee or beneficiary); where the relationship does not map to a specific code, an "other" code is used.
The data file is Caruso's own layout. It is not the ATO's or IRD's template; use it as your source when completing those templates.
Useful resources
Caruso builds the reports to the following schema versions:
FATCA — FATCA XML Schema v2.0 (IRS Publication 5124)
CRS — CRS XML Schema v2.0 (OECD Schema User Guide v3.0), the version currently required by the ATO and IRD
Australian Taxation Office (ATO)
New Zealand Inland Revenue (IRD)
US Internal Revenue Service (IRS)
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If you have any questions or need help at any stage, please contact our Caruso Support team either by email or live chat.