The U.S. Internal Revenue Service (IRS) updated the tax identification number (TIN) codes to be used in Y2022 FATCA reporting when certain Model 1 Foreign Financial Institutions (FFIs) have been unable to obtain a U.S. TIN for their pre-existing accounts that are reportable accounts. IRS TIN Reprieve For information regarding IRS Notice 2023-11 and the requirements for when an FFI may use the TIN codes, please see my recent blog post: FATCA: IRS Gives FFIs US TIN Reprieve. Tr

The U.S. Internal Revenue Service (IRS) recently issued Notice 2023-11 which will be in Internal Revenue Bulletin (IRB) 2023-3, dated January 17, 2023. The IRS provided procedures by which a Foreign Financial Institution (FFI) can remain compliant despite not obtaining U.S. tax identification numbers (TINs) from certain account holders who are U.S. Persons under FATCA. What Is the Reprieve? The IRS will not determine an FFI is significantly non-compliant with the FFI’s FATCA

There are a number of jurisdictions around the world whose Foreign Financial Institutions (FFIs) are not required to undertake FATCA reporting and are not subject to the FATCA “stick” of withholding. In total, there are 22 jurisdictions that have a Model 1 Intergovernmental Agreement (IGA) signed but not in force or are treated as having a Model 1 agreement in substance. The result is that almost 11,000 FFIs that have registered for GIINs have not been required to report U.S