Missing TIN relief requires evidence
Notice 2024-78 extends conditional relief for pre-existing US reportable accounts in 2025–2027. Institutions must continue the referenced identification and annual TIN-request procedures. From 2025, report an electronically available foreign tax identifier and include city and residence country in AddressFix for the affected US person. Retain evidence of the required policies and procedures through 2031. Placeholder codes can still produce an IRS error notice; the 120-day correction process does not make relief automatic or excuse abandoning efforts to obtain a TIN.
Registration and filing are separate
Check the AEOI profile and provide FATCA registration information; an umbrella fund uses its own GIIN, not a sub-fund’s. File by 31 May after the reporting year, including nil returns. The FAQ describes 5 MB submissions and fillable PDFs with up to 40 account reports. Validate XML, required namespaces and prohibited characters before upload, then distinguish IRS-requested corrections from amendments and voids. These operational instructions should be checked against current portal requirements where subsequently updated.
Official source
A concise, independent Apex Gateway guide based on the official English source, not a reproduction of the complete document. Consult the original for full conditions, exceptions and subsequent updates.
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