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Italy: Clarifications regarding U.S. TIN reporting, pre-existing accounts

Italy: Clarifications regarding U.S. TIN reporting

The Italian Ministry of Economy and Finance, in response to guidance issued by the U.S. Internal Revenue Service, issued clarifications regarding the obligation of financial institutions to acquire and provide U.S. taxpayer identification numbers (TINs) for pre-existing accounts.


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The clarifications confirm that financial institutions that have put in place procedures to obtain missing TINs are deemed to have made an “adequate effort” that could prevent these financial institutions from being found to be in non-compliance with their due diligence and reporting obligations.

Read a January 2020 report [PDF 77 KB] prepared by the KPMG member firm in Italy

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