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    Reporting account holder US TINs

    If you are an Australian financial institution with reporting obligations for the Foreign Account Tax Compliance Act (FATCA), it is important you are aware of the reporting requirements relating to United States of America (US) Taxpayer Identification Numbers (TINs).

    For all reports submitted from 2017 onwards, the US Internal Revenue Service (IRS) requires a US TIN be provided for each individual reported.

    The US will accept reporting of accounts without a TIN through to the 2019 reporting period, but only in exceptional circumstances where strict conditions are met. One of these conditions is that a date of birth must be provided in the absence of a US TIN. For more information refer to due diligence actions.

    Due diligence actions if missing US TIN

    If the US TIN is not held for a pre-existing account holder that is an individual, reporting Australian financial institutions must comply with the required due diligence actions. These are outlined in Notice 2017-46 (PDF 57.30KB)This link will download a file and are summarised as follows.

    Reporting Australian financial institutions must:

    • obtain and report the date of birth of each account holder and controlling person whose US TIN is not reported
    • request any missing US TINs from each account holder annually
    • search electronically searchable data maintained by the reporting institution for any missing US TINs before reporting each year.

    If due diligence actions are taken the IRS will not determine that there is significant non-compliance for the calendar years 2017, 2018 and 2019.

    How to report missing US TINs

    The US requirements for missing TINs differ for 2017 and 2018 reporting years. If, after due diligence actions have been undertaken, you have not been able to obtain US TINs for your clients:

    • For the 2017 year reports, you must use nine zeros (000000000) to populate the US TIN data element.
    • For the 2018 year and subsequent year reports, you must use nine capital As (AAAAAAAAA) to populate the US TIN data element.

    Consider if your system requires changes to accommodate entering alpha type characters in the US TIN data element.

    Some other countries may have already started using nine As. This may affect reporting from/for branches in other countries.

    FATCA small reporter tool (SRT)

    We have developed a small reporter tool for FATCA reporters with up to 50 reportable individual accounts and up to 50 reportable organisation accounts.

    FATCA reporters with no reportable accounts can also use the SRT to lodge a nil report.

    The FATCA SRT allows reporters to enter information into an Excel spreadsheet and convert the data into an XML file.

    Next step:

    Providing your Australian business number (ABN)

    The identifier to be used by a reporting financial institution (FI) or sponsor is the global intermediary identification number (GIIN) it received from the US Internal Revenue Service (IRS) at registration. The GIIN is supplied at the reporting FI and sponsor (if a sponsor is reporting) Taxpayer Identification Number (TIN) elements.

    We recommend a reporting FI and sponsor supplies their ABN in addition to their GIIN. The IRS issued Reporting FI TIN element is mandatory and should always be included in your report (trustee documented trusts are excluded – see below).

    Supplying your ABN helps us to record your lodgment and reduces the need for us to contact you.

    Example

    <ns2:ReportingFI>

    <ResCountryCode>AU</ResCountryCode>

    <TIN issuedBy="US">xxxxxx.xxxxx.xx.xxx</TIN>

    <TIN issuedBy="AU">(Insert ABN here)</TIN>

    <Name>XXXXXX</</Name>

    <Address>

     

    <ns2:Sponsor>

    <ResCountryCode>AU</ResCountryCode>

    <TIN issuedBy="US">xxxxxx.xxxxx.SP.xxx</TIN>

    <TIN issuedBy="AU">(Insert ABN here)</TIN>

    <Name>XXXXXX</</Name>

    <Address>

    End of example

    Reporting sponsor GIIN correctly

    The global intermediary identification number (GIIN) value of a sponsoring entity is the GIIN issued to the entity when it is acting in its capacity as a sponsor. Sponsors have 'SP' in their GIIN in the following format: xxxxxx.xxxxx.SP.xxx

    If you have more than one GIIN, ensure they are provided correctly.

    Ensure the sponsor GIIN appears in the Sponsor element. The ReportingFI GIIN should appear at the ReportingFI TIN element. (The ReportingFI TIN is the GIIN issued to the entity when it registers as a ReportingFI.)

    Trustee documented trusts (TDTs)

    When reporting for trustee documented trusts (TDTs), the trustee is reporting on behalf of the trust and is therefore required to register and obtain a GIIN. The trust itself is not required to obtain a GIIN.

    The trustee GIIN is reported in the Sponsor data element. The trustee’s GIIN should not be reported in the ReportingFI element.

    The details of the trust are reported in the ReportingFI element.

    For TDTs, the IRS FATCA XML User Guide (PDF 1.15MB)This link will download a file advises to leave the ReportingFI TIN field 'blank'. This means the TIN field in the ReportingFI element should be removed completely.

    In the Small Reporter Tool (SRT), the TIN cell is left blank – refer to the SRT guide.

    Note also that:

    • the sponsor element must be present and completed
    • DocRefIds should all begin with the Sponsor GIIN
    • the sponsor FilerCategory code must be ‘FATCA609’.

    See also:

    Consider when to archive your reports

    FATCA reports received from Australian reporters are passed on to the US IRS immediately after lodgment. If the IRS advises of any errors requiring correction, we contact reporters to fix the errors.

    Consider the timing for archiving your FATCA reports to enable any necessary corrections.

    Wrapper headers

    From 1 January 2019, all FATCA reports must be lodged with wrapper header information.

    See also:

    Single file limitation

    Under the system implemented on 1 January 2018, the lodgment of FATCA files allows only a single report per file. That report should contain all of an entity's reportable accounts.

    The bulk data exchange (BDE) FATCA functionality which enabled the submission of a file for more than one reporting institution was decommissioned in December 2018.

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    Next steps:

    Last modified: 06 Jun 2019QC 56992