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

September 29, 2017 Gerry Nelligan

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.


About the Author

Gerry  Nelligan

Gerry Nelligan is a Regulatory Analysis Supervisor at Sovos, leading a team of counsels covering information reporting, including 10-Series IRS reporting, Affordable Care Act (ACA) reporting and Automatic Exchange of Information (AEOI). Gerry received his J.D. from Suffolk University Law School and his B.A. from Providence College. He is a licensed attorney in the state of Massachusetts.

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