IRS publishes updated FATCA guidance on TIN reporting by Model 1 FFIs
On 26 September, the US Internal Revenue Service (IRS) published Notice 2017-46: Revised Guidance Related to Obtaining and Reporting Taxpayer Identification Numbers and Dates of Birth by Financial Institutions (link https://www.irs.gov/pub/irs-drop/n-17-46.pdf).
The notice provides procedures for certain foreign financial institutions (FFIs) required to report US taxpayer identification numbers (TINs) for certain accounts under a Model 1 intergovernmental agreement (IGA). In particular, the notice states that:
With respect to reporting on pre-existing accounts that are US reportable accounts, for calendar years 2017, 2018, and 2019, the US Competent Authority will not determine that there is significant non-compliance with the obligations under an applicable Model 1 IGA with respect to a reporting Model 1 FFI solely because of a failure to obtain and report each required US TIN, provided that the reporting Model 1 FFI:
(1) obtains and reports the date of birth of each account holder and controlling person whose U.S. TIN is not reported;
(2) requests annually from each account holder any missing required U.S. TIN; and
(3) before reporting information that relates to calendar year 2017 to the partner jurisdiction, searches electronically searchable data maintained by the reporting Model 1 FFI for any missing required US TINs.