IRS Releases Notice Detailing Procedures for FFIs required to report U.S. TINs under FATCA Model 1 IGAs

Sovos
September 28, 2017

The IRS released an advance version of Notice 2017-46 which details procedures for FFIs required to report U.S. TINs under FATCA Model 1 IGAs. In this advance notice, the IRS establishes that they will not determine that there is significant non-compliance with reporting obligations under an applicable Model 1 IGA during calendar years 2017, 2018, and 2019 because of a failure to obtain and report each required U.S. TIN. However, this will only occur provided that the reporting Model 1 FFI:

  • Obtains and reports the DOB of each account holder and controlling person whose U.S. TIN is not reported
  • Requests annually from each account holder any missing required U.S. TIN; and
  • Before reporting that relates to calendar year 2017 to the partner jurisdiction, searches its electronic records for missing U.S. TINs.

 

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Sovos

Sovos was built to solve the complexities of the digital transformation of tax, with complete, connected offerings for tax determination, continuous transaction controls, tax reporting and more. Sovos customers include half the Fortune 500, as well as businesses of every size operating in more than 70 countries. The company’s SaaS products and proprietary Sovos S1 Platform integrate with a wide variety of business applications and government compliance processes. Sovos has employees throughout the Americas and Europe, and is owned by Hg and TA Associates.
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