FATCA Mandatory Tax Identification Number (TIN) Update (2021-09-20)

Summary

This notice from the BVI International Tax Authority (ITA) informs all Financial Institutions with FATCA reporting obligations that inclusion of the U.S. Tax Identification Number (TIN) for every reportable account is now mandatory in FATCA reports. The requirement applies to reporting periods for the 2020 year onwards, superseding the prior IRS transitional relief under Notice 2017-46.

• Mandatory TIN: All reportable accounts in FATCA filings for reporting period 2020 onwards must include the actual U.S. TIN; the prior IRS Notice 2017-46 relief no longer applies.
• Placeholder codes: Filings for 2020 submitted using substitute codes (nine A's, or 2's through 7's) instead of a TIN will still be accepted by the IRS but will generate a record-level error notification.
• Correction window: Any such error notification must be corrected within 120 days.
• ITA review: The ITA is conducting an internal review of filings to identify FIs not in compliance with the mandatory TIN requirement and will contact them directly.
• Self-reporting: FIs that filed 2020 reportable accounts without the mandatory TIN and have not been contacted by the ITA should proactively notify the ITA at info@bviita.vg with the subject line "FATCA Mandatory TIN Update", confirming the re-submitted filing.

The notice is informational guidance implementing a US IRS policy change and directs affected institutions on remediation steps and self-reporting expectations.

Key obligations

• FIs must include the mandatory U.S. TIN for all reportable accounts in FATCA filings for reporting period 2020 onwards.
• FIs that receive an IRS record-level error notification (from use of placeholder TIN codes) must correct the error within 120 days.
• FIs that filed 2020 reportable accounts without the mandatory TIN and were not contacted by the ITA must notify the ITA at info@bviita.vg with subject line "FATCA Mandatory TIN Update" and confirm the re-submitted filing.

Applies to

Financial Institutions with FATCA reporting obligations

Deadlines

• 120 days: Deadline to correct a record-level error notification from the IRS resulting from filings that used placeholder TIN codes instead of the mandatory TIN.