US tax residents face a dual compliance burden. They must simultaneously satisfy Bermuda’s Economic Substance Act 2018 requirements — CIGA, resident representative, annual compliance filing, and beneficial ownership register — and US federal foreign reporting obligations including Form 5471, FBAR (FinCEN 114), Form 8938 (FATCA), and potentially Form 8621 (PFIC). Since Bermuda automatically exchanges non-compliance information with the IRS under OECD CRS and the US-Bermuda FATCA IGA, a Bermuda compliance failure directly triggers IRS scrutiny.