Guernsey FATCA Guidance: Updated TIN And Reporting Requirements

February 24, 2021 – Guernsey – Updated Information on TIN element:

Guernsey FATCA Guidance: Tax Identification Numbers (TINs) & Reporting Requirements:

The US recognizes that foreign financial institutions require more time to obtain the required TIN and have therefore developed a series of codes that may be used by a reporting Model 1 FFI (which includes Guernsey).

Despite the transitional period expiring the IRS has developed a series of codes that may be used by Financial Institutions to populate the TIN data field, which are set out below:

TIN Field Codes & Purpose:
222222222
Pre-existing individual account where only the US indicia is a US place of birth.

333333333
New individual account that have indicia indicating a U.S. place of birth, and either:

  • has had a change in circumstances causing the self-certification originally obtained at account opening to be incorrect or unreliable, and a new self-сcertification has not been obtained, or
  • 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 have U.S., indicia other than a U.S. place of birth, and either:

  • has had 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
  • 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 either:

  • has had 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
  • 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
Pre-existing entity account with account balance exceeding $1,000,000 held by a passive NFFE with respect to which no self-certifications have been obtained, and no U.S. indicia have been identified in relation to its controlling persons.

Guernsey Financial Institutions that cannot implement the reporting of the new codes or have accounts to report without valid U.S. TINs that do not fall within the categories listed above should continue to use the previous default code of nine capital letter A’s (AAAAAAAAA).

Do note that this will result in the US authorities notifying the Guernsey Competent Authority of an error in respect of each account with a missing TIN following the exchange of data in September 2021. In turn, these errors will be notified to the relevant Guernsey Financial Institutions which will require an explanation and, if necessary, correction of the data thereafter.

For more information, please click here.



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