IRS Notice 2017-46: Historical FATCA TIN Relief

Key steps and distinctions

For calendar years 2017–2019, a reporting Model 1 foreign financial institution would not be found significantly non-compliant solely for missing required US TINs on specified pre-existing reportable accounts if it met three conditions: obtain and report each relevant individual’s date of birth, request missing TINs annually and search electronically searchable records before the 2017 report. This was conditional temporary relief, not a permanent exemption or relief for every account. Institutions still had to implement documentation procedures and timely future reporting. A separate part addressed foreign TINs and dates of birth for accounts at US offices or branches of financial institutions and withholding certificates linked to US-source payments reportable on Form 1042-S. It announced limits, exceptions and phase-in arrangements, distinguishing them from US-TIN FATCA reporting. The notice did not remove obligations under other withholding and reporting provisions. Keep evidence of requests, searches and birth dates when reviewing the specified historical years. Identify this as guidance issued by the US IRS, not a new Singapore rule. For present reporting, later notices and applicable Singapore FATCA instructions must be considered; the 2017–2019 relief cannot simply be extended indefinitely.