IRS Publishes New Technical FAQ on TIN Reporting Format for Tax Year 2017

April 24, 2017

Tom Hospod

Author

Sovos

This blog was last updated on June 26, 2021

Beginning in 2018, Model 1 FFIs will no longer be permitted to use nine zeros in place of a U.S. TIN.

Article 6(3)(b) of the Model 1 IGA provides that by January 1, 2017, each Model 1 jurisdiction commits to establishing rules requiring reporting Model 1 FFIs to obtain U.S. TINs for preexisting accounts for reporting with respect to 2017 and later years.

Beginning in January 2018, validations will be updated in order to produce an error notification if a reporting Model 1 FFI reports nine zeros as a TIN for an account holder.

Tom Hospod

Tom Hospod is a Regulatory Counsel at Sovos Compliance. Within Sovos' Regulatory Analysis function, Tom focuses om Affordable Care Act (ACA) reporting, Tax Withholding, and Automatic Exchange of Information (AEOI). Prior to Sovos, Tom worked as a legislative aide in the Massachusetts House of Representatives. Tom is a member of the Massachusetts Bar, earned his B.A. from Boston College and his J.D. from the University of Miami.

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