FATCA - Update on U.S. TIN field of the FATCA XML Schema

Tags: FATCA, U.S. TIN

In the IRS’ efforts to better understand the issues that FFIs face in obtaining a U.S. TIN, has developed a series of codes that may be used by a reporting Model 1 FFI to populate the TIN field.

Commencing with the FATCA submissions of the 2020 calendar year data, the undermentioned TIN Field codes are recommended where the FFIs have missing US TIN’s for their account holders.

Recommended TIN Field Code and related scenarios are as follows:

  • 222222222 – Pre-existing individual account with only U.S. indicia being a U.S. place of birth.
  • 333333333 – New individual account that (1) has indicia of a U.S. place of birth, and (2) either:
    1. has a change in circumstances causing the self-certification originally obtained at account opening to be incorrect or unreliable, and a new self-certification has not been obtained, or
    2. was below the threshold for documenting and reporting the account at the time of account opening and subsequently exceeded the threshold, and a self-certification has not been obtained.
  • 444444444 – Pre-existing individual and entity account that (1) has U.S, indicia other than a U.S. place of birth, and (2) either:
    1. has a change in circumstances, causing the self-certification or other documentation originally obtained to be incorrect or unreliable, and a new self-certification or other documentation has not been obtained or
    2. was below the threshold for documenting and reporting the account at the time of account opening and subsequently exceeded the threshold, and a self-certification or other documentation has not been obtained.
  • 555555555 – New individual and entity account that has a U.S, indicia other than a U.S. place of birth, and (2) either:
    1. has a change in circumstances causing the self-certification or other documentation originally obtained to be incorrect or unreliable, and a new self-certification or other documentation has not been obtained or
    2. was below the threshold for documenting and reporting the account at the time of account opening and subsequently exceeded the threshold, and a self-certification or other documentation has not been obtained.
  • 666666666 – Preexisting entity account with account balance exceeding $1,000,000 held by a passive NFFE with respect to which no self-certifications have not been obtained, and no U.S. indicia have been identified in relation to its controlling persons.
  • 777777777 – For pre-existing accounts where there is no TIN available and the account has been dormant or inactive, but remains above the reporting threshold, also known as a “dormant account”

Notes:

  • The use of these codes is not mandatory and does not mean that an FFI will not be at risk for being found significantly non-compliant due to a failure to report each required U.S. TIN.
  • The IRS system will still generate an error notification to indicate the entry is invalid when one of the codes is used.
  • Entering nine A’s or 0’s in missing U.S. TIN field will no longer suppress the error notification beginning with the 2020 calendar year data.
  • The error notification will provide 120 days to correct the issues, which is consistent with Article 5(1) of the IGA, administrative and other minor errors, including incorrect or incomplete reporting of information described under Articles 2(2) and 4(1)(b) of the IGA or other errors that result in infringements of the IGA.