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ARTICLE · 12 NOVEMBER 2019

Canadian FATCA Compliance Update

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The Internal Revenue Service has issued revised Foreign Account Tax Compliance Act guidance on the requirement for foreign financial institutions in Model 1 jurisdictions to provide a U.S. tax identification number.

CanadaTax
Joelle Kabouchi
Joelle Kabouchi
Grace Pereira
Grace Pereira
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​The Internal Revenue Service (IRS) has issued revised Foreign Account Tax Compliance Act (FATCA) guidance on the requirement for foreign financial institutions (FFIs) in Model 1 jurisdictions (Model 1 FFIs) to provide a U.S. tax identification number (U.S. TIN).

As noted in our December 7, 2018 Compliance Update, a key concern of Model 1 FFIs under FATCA has been the requirement to obtain and provide U.S. TINs to the IRS. In respect of this requirement, IRS Notice 2017-46 had provided relief to pre-existing accounts that were U.S. reportable accounts for calendar years 2017, 2018, and 2019. Such accounts would not be determined to be in significant non-compliance with FATCA as a result of a failure to obtain and report a U.S. TIN, provided that the reporting Model 1 FFI:

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