Cayman Financial Review offers another clear-headed article about FATCA, this one by Peter A. Cotorceanu, a tax specialist in Zurich.
http://www.compasscayman.com/cfr/2014/08/08/FATCA–Has-Cayman-orphaned-its-trusts-/
Mr. Cotorceanu describes in detail how the Cayman Islands interpreted the original IGA boilerplate wording to its advantage, underlining the role of basic semantics in the complex imposition of FATCA. As a result, other jurisdictions may follow the Cayman’s example in restricting the application of the FATCA IGA only to trusts “…whose trustee is ‘incorporated, registered or licensed’ in the Cayman Islands.”