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FATCA & CRS Alert 2017-08

FATCA & CRS Alert 2017-08



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Reporting TINs by FFIs under FATCA Model 1 intergovernmental agreements

The IRS has released an advance version of Notice 2017-46 that sets forth procedures for certain foreign financial institutions required to report U.S. taxpayer identification numbers (“U.S. TINs”) for certain accounts under a FATCA Model 1 intergovernmental agreement (IGA).

Notice 2017-46 (PDF | 57 KB) is summarized, as follows:

With respect to foreign financial institutions (FFIs)
—the notice provides that FFIs in Model 1 IGA jurisdictions will not be in “significant non-compliance” with an applicable IGA during 2017, 2018, and 2019 solely because of a failure to report U.S. TINs for preexisting accounts, provided the FFI:

  • Reports the account holder’s date of birth
  • Makes annual requests for the TIN
  • Searches its electronic records for missing U.S. TINs before reporting information on 2017

With respect to U.S. financial institutions
—today’s notice:

  • Provides a phase-in period for obtaining foreign TINs from account holders documented prior to January 1, 2018
  • Narrows the circumstances when a foreign TIN is required

Future regulations

The IRS notice also announces that the IRS and U.S. Treasury Department intend to amend provisions under the temporary regulations under chapter 3, to provide limitations on—and a phase-in of—the requirement for certain withholding agents to obtain and report the TIN issued by an account holder’s jurisdiction of tax residence (a “foreign TIN”) and for an account holder who is an individual, the account holder’s date of birth.

According to the IRS, taxpayers may rely on the provisions of Notice 2017-46 before the amendments to the temporary Chapter 3 regulations reflecting the guidance in today’s notice.

The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation.

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