This blog was last updated on June 26, 2021
The IRS’s International Data Exchange Service (IDES) has published an answer to a Frequently Asked Question regarding TIN reporting in 2018 – for Tax Year 2017 information.
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.