Форма 8966 инструкция по заполнению на русском

В данном разделе указываются сведения о счете выявленного клиента, информация по которому представлена в Разделе 4 настоящего Уведомления. В случае наличия у такого клиента нескольких счетов раздел 5 «Сведения о счетах иностранного налогоплательщика юридического лица» заполняется в отношении каждого такого счета в отдельности. Все поля данного раздела являются обязательными для заполнения.

Порядок выбора валюты, в которой будут указаны денежные средства клиента, а также правила округления сумм денежных средств аналогичны требованиям, установленным, например, инструкцией к форме 8966 СВД США и упомянутыми в ней инструктивными документами Министерства Финансов США.

— В поле «номер счета» Заявитель указывает идентификационный номер счета клиента в организации финансового рынка. Поле является обязательным для заполнения

Данное поле, например, аналогично пункту 1 «Account number» раздела 4 «Financial Information» формы 8966 СВД США и может заполняться в соответствии с инструкцией к данной форме СВД США и упомянутыми в ней инструктивными документами Министерства Финансов США.

— Поле «вид (тип) счета» заполняется согласно перечню значений «тип счета». Поле является необязательным для заполнения.

— В поле «валюта счета» указывается буквенный код из 3 символов в соответствии со списком наименований валют по стандарту ISO 4217. Поле является обязательным для заполнения при наличии такой информации.

— В поле «остаток денежных средств на счете (вкладе)» указывается соответствующая информация о счете. Поле является обязательным для заполнения при наличии такой информации.

Данное поле, например, аналогично пункту 1 «Account balance» раздела 4 «Financial Information» формы 8966 СВД США и может заполняться в соответствии с инструкцией к данной форме СВД США и упомянутыми в ней инструктивными документами Министерства Финансов США.

— В поле «дата открытия (закрытия) счета/вклада» указывается соответствующая информация о счете. Поле является необязательным для заполнения.

— Реквизит «вид и количественное выражение имущества, принадлежащего клиенту» содержит следующие поля:

— «Проценты»;

— «Дивиденды»;

— «Валовый доход/Выплаты»;

— «Иное».

Данные поля заполняются при наличии такой информации о клиенте и ее представлении в иностранный налоговый орган.

Данные поля, например, аналогичны пунктам 4а «Interest» 4b «Dividends» 4с «Gross proceeds/Redemptions» 4d «Other» раздела 4 «Financial Information» формы 8966 СВД США и могут заполняться в соответствии с инструкцией к форме 8966 СВД США и упомянутыми в ней инструктивными документами Министерства Финансов США.

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Уведомления в ФНС

Модуль «Баланс-2: Отчетность ОФР», реализованный в составе программах «Баланс-2W» и «Баланс-2Н», позволяет подготовить:

  1. четыре вида уведомлений в ФНС РФ о клиентах – иностранных налогоплательщика:
    • Уведомления организации финансового рынка о регистрации (изменении статуса, аннулировании регистрации, повторной регистрации) в иностранном налоговом органе (КНД 1114701).
    • Уведомление организации финансового рынка в уполномоченные органы при выявлении клиента — иностранного налогоплательщика (КНД 1114702).
    • Уведомление организации финансового рынка о получении запроса от иностранного налогового органа (КНД 1114703).
    • Уведомление организации финансового рынка о направлении информации о клиентах иностранных налогоплательщиках в иностранный налоговый орган (КНД 1114704).
  2. уведомление об использовании права не представлять информацию по ранее заключенным договорам с клиентами-юридическими лицами с остатком средств менее или равным 250 тысяч долларов США в уполномоченный орган в электронной форме по стандарту ОЭСР

Подготовка четырех видов уведомлений в ФНС РФ о клиентах – иностранных налогоплательщиках по формату 5.02 предоставляет возможности:

  • Ввод необходимых данных в экранную форму и их проверку по контрольным соотношениям.
  • Переноса сведений из отчета по FATCA 8966 в уведомления о направлении информации о клиентах иностранных налогоплательщиках в ИНО — КНД 1114704.
  • Формирование XML-файла уведомления и его форматно-логический контроль.
  • Формирование транспортного контейнера для передачи подписанного файла Уведомления в ФНС через сервис «Сообщение о клиенте-иностранном налогоплательщике».

Сроки представления Уведомлений в ФНС РФ см. в «Подготовка и отправка уведомлений организаций финансового рынка …».

Что такое FATCA?

Закон о налогообложении иностранных счетов (The Foreign Account Tax Compliance, далее — FATCA), являющийся частью законодательства США, нацелен на предотвращение уклонения от уплаты налогов гражданами и налогоплательщиками США с привлечением международных инвестиционных механизмов.

FATCA устанавливает требования к финансовым институтам по всему миру, согласно которым они должны выявлять счета американских налогоплательщиков и предоставлять информацию по ним в налоговые органы США.

Официальный сайт FATCA

Глоссарий

Вы можете получить ответы на все вопросы, связанные с применением компанией АТОН американского закона FATCA по нижеуказанным каналам связи:

  • E-mail: fatca@aton.ru

ООО «АТОН» не предоставляет консультаций по вопросам налогообложения и заполнения форм W-8BEN, W-8BEN-E, W-8IMY и др. По всем возникающим вопросам вам необходимо обратиться к вашему налоговому консультанту.

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FATCA Report

Section references are to the Internal Revenue Code unless otherwise noted.

2022


Instructions for Form 8966 — Introductory Material

Section references are to the Internal Revenue Code unless otherwise noted.

Future Developments

For the latest information about developments related to Form 8966 or its instructions, such as legislation enacted after they were published, go to IRS.gov/Form8966.

General Instructions

Reminders

Identifying numbers for paper Forms 8966.

Beginning in 2018, the unique identifying number must be entered in the “Identifier” box provided at the top of the form. If the filer is submitting an amended, corrected, or voided Form 8966, it must continue to include the same unique identifying number that was reported on the original Form 8966 that is being amended, corrected, or voided.

Reporting on accounts held by nonparticipating Foreign Financial Institutions (FFIs).

Reporting by participating FFIs (PFFIs) (including Reporting Model 2 FFIs) on accounts held by nonparticipating FFIs was only required for 2015 and 2016. For 2017 and subsequent years, PFFIs (including Reporting Model 2 FFIs) are not required to report an account held by a nonparticipating FFI in Part II or Part V. Therefore, PFFIs (including Reporting Model 2 FFIs) should not check the box for “nonparticipating FFI” on line 5 of Part II, should not check the pooled reporting type “nonparticipating FFI” on line 1 of Part V, and should not complete line 3 of Part V.

Reporting Model 2 FFI related entities or branches.

Reporting Model 2 FFIs may have related entities or branches provided that the conditions in the Model 2 intergovernmental agreement (IGA) are met, including the requirement that the related entity or branch reports U.S. accounts to the IRS to the extent permitted. A related entity or branch of a Reporting Model 2 FFI filing Form 8966 should select the filer category code for limited branch or limited FFI on line 1b of Part I.

Reporting Model 2 FFIs reporting on non-consenting U.S. accounts.

If a Reporting Model 2 FFI is reporting a preexisting account that is a non-consenting U.S. account, the Reporting Model 2 FFI should use the pooled reporting category for recalcitrant account holders that are U.S. persons or recalcitrant account holders with U.S. indicia (as appropriate). If a Reporting Model 2 FFI is reporting a new individual account that has a change in circumstances that causes the Reporting Model 2 FFI to know or have reason to know that the original self-certification is incorrect or unreliable and the Reporting Model 2 FFI is unable to obtain a valid self-certification establishing whether the account holder is a U.S. citizen or resident, the Reporting Model 2 FFI should use the pooled reporting category for recalcitrant account holders with U.S. indicia.

U.S. branches.

On line 1b of Part I, all U.S. branches of an FFI not treated as U.S. persons should select the filer category code for PFFIs (code 01). All U.S. branches that are treated as U.S. persons should select the filer category code for withholding agents (code 10).

Summary of Chapter 4 and Related Matters

Under chapter 4 of the Internal Revenue Code (Code) (sections 1471–1474 and Treasury Regulations (Regulations), commonly referred to as the Foreign Account Tax Compliance Act or FATCA), a withholding agent is generally required to deduct and withhold tax equal to 30% of a withholdable payment made to a foreign financial institution (FFI) unless the FFI has entered into an FFI agreement with the IRS to be treated as a participating FFI (PFFI). Pursuant to the FFI agreement, a PFFI agrees to satisfy, among other things, certain reporting obligations for each calendar year concerning its U.S. accounts, accounts held by owner-documented FFIs (ODFFI), and certain aggregate information concerning accounts held by recalcitrant account holders. An FFI may also be excepted from chapter 4 withholding if it is deemed to comply with the provisions of section 1471(b) under Regulations section 1.1471-5(f) or is otherwise exempt from withholding if it is an exempt beneficial owner for chapter 4 purposes under Regulations section 1.1471-6. Chapter 4 also requires a withholding agent to deduct and withhold tax equal to 30% of a withholdable payment made to a passive non-financial foreign entity (NFFE) unless the passive NFFE certifies to the withholding agent that it does not have any substantial U.S. owners or provides certain identifying information with respect to its substantial U.S. owners. A withholding agent is also required to report information about substantial U.S. owners of a passive NFFE and specified U.S. persons holding certain equity or debt interests in a payee that the withholding agent has agreed to treat as an ODFFI.

To facilitate FATCA implementation for FFIs operating in jurisdictions with laws that would prevent the FFIs from complying with the terms of the FFI agreement, the Treasury Department developed two alternative model intergovernmental agreements (IGAs) (Model 1 IGA and Model 2 IGA) that would allow FFIs operating in such jurisdictions to perform due diligence and reporting on their account holders to achieve the objectives of FATCA. FFIs reporting under a Model 1 IGA (Reporting Model 1 FFIs) report certain information about their U.S. reportable accounts and certain payees as required under the applicable IGA to their respective tax authorities. Reporting Model 1 FFIs do not file Form 8966 directly to the IRS. FFIs reporting under a Model 2 IGA (Reporting Model 2 FFIs) report directly to the IRS on Form 8966 certain information about their U.S. accounts and certain aggregate information concerning account holders who do not waive legal restrictions for the FFI to report this information (non-consenting U.S. accounts). Trustee-Documented Trusts subject to a Model 2 IGA are reported by the trustee of the Trustee-Documented Trust.

Purpose of Form

Form 8966 is required to be filed by filers listed under “Who Must File,” later, to report information with respect to certain U.S. accounts, substantial U.S. owners of passive NFFEs, specified U.S. persons that own certain debt or equity interests in ODFFIs, and certain other accounts as applicable based on the filer’s chapter 4 status. Unless otherwise indicated, Reporting Model 2 FFIs should submit Form 8966 to report on its accounts consistent with instructions for PFFIs.

Note.

A separate Form 8966 must be filed for each substantial U.S. owner of a passive NFFE and each specified U.S. person owning certain equity or debt interests in an ODFFI, and for each group of accounts of an FFI for which pooled reporting is permitted as described in Part V.

Who Must File

Except as otherwise provided in these instructions, you are required to file Form 8966 if you are one of the following persons.

  • PFFI. A PFFI must file Form 8966 to report information with respect to U.S. accounts, accounts held by ODFFIs, and accounts held by recalcitrant account holders (based on the pools described in Part V).

  • U.S. branch of an FFI not treated as a U.S. person. A U.S. branch of an FFI that is not treated as a U.S. person is subject to the same Form 8966 reporting requirements as a PFFI. See Regulations section 1.1471-4(d)(2)(iii)(C).

  • Registered deemed-compliant FFI (RDCFFI). An RDCFFI must file Form 8966 to report a U.S. account for which it has reporting obligations as a condition of its applicable RDCFFI status. See Regulations section 1.1471-5(f)(1)(i) or an applicable Model 2 IGA.

  • Related entity or branch described in an applicable Model 2 IGA. A related entity or branch described in an applicable Model 2 IGA must file Form 8966 to report a U.S account to the extent permitted under the relevant laws pertaining to the branch or FFI.

  • Reporting Model 2 FFI. A Reporting Model 2 FFI must file Form 8966 to report information with respect to U.S. accounts, accounts held by ODFFIs, and non-consenting U.S. accounts (based on the pools described in the instructions for Reporting Model 2 FFIs in Part V).

  • Qualified Intermediary (QI), Withholding Foreign Partnership (WP), or Withholding Foreign Trust (WT). A QI, WP, or WT must file Form 8966 to report on its accounts, partners, beneficiaries, or owners, as applicable and as provided in its QI, WP, or WT agreement.

  • Direct Reporting NFFE. A Direct Reporting NFFE must file Form 8966 to report its substantial U.S. owners or report that it has none. See Regulations section 1.1472-1(c)(3).

  • Sponsoring Entity. A Sponsoring Entity must file Form 8966 to report an account of an FFI or a substantial U.S. owner of a passive NFFE that it has agreed to treat as a Sponsored FFI or a Sponsored Direct Reporting NFFE. See Regulations section 1.1471-4(d)(2)(ii)(C) regarding the reporting required of a Sponsoring Entity acting on behalf of a Sponsored FFI. See Regulations section 1.1472-1(c)(5) regarding the reporting required of a Sponsoring Entity acting on behalf of a Sponsored Direct Reporting NFFE.

    This is an Image: taxtip.gifSponsored FFIs and Sponsored Direct Reporting NFFEs do not need to file Form 8966 if a Sponsoring Entity is reporting on its behalf.

  • Trustee-Documented Trust. A trustee of a Trustee-Documented Trust reports on Form 8966 all information required to be reported under an applicable IGA as if it were a Reporting Model 2 FFI with respect to each U.S. account maintained by the Trustee-Documented Trust.

Special Rules for Certain Form 8966 Filers

  • Withholding agents. A withholding agent that is not an FFI and that makes a withholdable payment to a passive NFFE with a substantial U.S. owner (either directly or indirectly through a flow-through entity that is also a passive NFFE) if the first-mentioned NFFE is the beneficial owner of the payment, or a withholding agent that is a designated withholding agent and that makes a withholdable payment to an ODFFI with a specified U.S. person owning certain equity or debt interests in the ODFFI must report such substantial U.S. owners or specified U.S. persons on Form 8966.

    A U.S. payor (other than a U.S. branch) that is a PFFI (including a Reporting Model 2 FFI) or RDCFFI is not required to file Form 8966 to report an account if it reports payments to the account holder on Form 1099 to the extent specified in Regulations section 1.1471-4(d)(2)(iii)(A). With respect to an account held by a passive NFFE with a substantial U.S. owner or an account held by an FFI that the PFFI (including a Reporting Model 2 FFI) has agreed to treat as an ODFFI, the PFFI (including a Reporting Model 2 FFI) or RDCFFI that elects reporting on Form 1099 must still file Form 8966 to report such accounts.

    This is an Image: caution.gifA withholding agent that is a U.S. payor reporting payments to U.S. non-exempt recipients must report these payments on the appropriate Form 1099 to the extent required under chapter 61. You do not need to file Form 8966 to report these payments.

    This is an Image: caution.gifAn FFI other than a PFFI, Reporting Model 2 FFI, or RDCFFI that is not required to file Form 8966 may still be required to report a payment under chapter 61.

    This is an Image: taxtip.gifForm 8966 is not used to report any tax withheld under chapter 4 to the IRS. A withholding agent may, in addition to Form 8966, also have to file Form 1042, Annual Withholding Tax Return for U.S. Source Income of Foreign Persons, and Form 1042-S, Foreign Person’s U.S. Source Income Subject to Withholding, to report any tax withheld under chapter 4. For further information, see Forms 1042, 1042-S, and their instructions.

  • PFFI (including a Reporting Model 2 FFI) or RDCFFI electing chapter 61 reporting. A PFFI (including a Reporting Model 2 FFI) or RDCFFI that elects to perform chapter 61 reporting to satisfy its chapter 4 reporting requirements for certain accounts is not required to report on Form 8966 with respect to such an account that is held by a specified U.S. person. Instead, the PFFI (including a Reporting Model 2 FFI) or RDCFFI shall report such account on Form 1099. See Regulations section 1.1471-4(d)(5). With respect to an account held by a passive NFFE with a substantial U.S. owner or an account held by an FFI that the PFFI (including a Reporting Model 2 FFI) or RDCFFI has agreed to treat as an ODFFI, the PFFI (including a Reporting Model 2 FFI) or RDCFFI that elects reporting under chapter 61 must still file Form 8966 to report such accounts.

  • U.S. branch that is treated as a U.S. person. A U.S. branch that is treated as a U.S. person must file Form 8966 in the same manner as a withholding agent (see earlier). See Regulations sections 1.1471-1(b)(135) and 1.1441-1(b)(2)(iv).

  • Territory Financial Institution that is treated as a U.S. person. A Territory Financial Institution that is a flow-through entity or that acts as an intermediary with respect to a withholdable payment and that agrees to be treated as a U.S. person must file Form 8966 in the same manner as a withholding agent (see earlier). See Regulations sections 1.1471-1(b)(131) and 1.1471-2(a)(2)(iv).

Combined Reporting Following a Merger or Bulk Acquisition of Accounts

If a PFFI (including a Reporting Model 2 FFI) (successor) acquires accounts of another PFFI (including a Reporting Model 2 FFI) (predecessor) in a merger or bulk acquisition of accounts, the successor may assume the predecessor’s obligations to report the acquired accounts on Form 8966 for the calendar year in which the merger or acquisition occurs, provided the requirements in Regulations section 1.1471-4T(d)(2)(ii)(G)(1) through (4) are satisfied.

When, How, and Where To File

When to file.

Form 8966 is required to be filed for the 2022 calendar year on or before March 31, 2023. A Reporting Model 2 FFI must file Form 8966 on the same filing dates that apply to a PFFI, unless a different reporting date is specified in an applicable Model 2 IGA.

Extension of time to file.

An automatic 90-day extension of time to file Form 8966 may be requested. To request an automatic 90-day extension of time to file Forms 8966, file Form 8809-I. See the Instructions for Form 8809-I for where to file that form. You should request an extension as soon as you are aware that an extension is necessary, but no later than the due date for filing Forms 8966. No extension of time to file is permitted for Forms 8966 filed by a Reporting Model 2 FFI to report a non-consenting U.S. account. A Reporting Model 2 FFI should refer to the applicable Model 2 IGA for the due dates for those filings.

Under certain hardship conditions, the IRS may grant an additional 90-day extension to file Form 8966. See Regulations section 1.1471-4(d)(3)(vii). To request an additional 90-day extension of time to file Form 8966, file a second Form 8809-I before the end of the initial extended due date. See the Instructions for Form 8809-I for more information on the requirements for requesting an additional extension for filing Form 8966.

Each branch requesting an automatic or additional extension must file a separate Form 8809-I.

Electronic filing requirement.

An entity that is a financial institution is required to file Form 8966 electronically, irrespective of the number of Forms 8966 filed. All other filers are strongly encouraged to electronically file Forms 8966. To request a waiver from the required filing of Forms 8966 electronically, submit Form 8508-I. Waiver requests should be filed at least 45 days before the due date of the returns. See the instructions for Form 8508-I for where to file and additional information.

How to file electronically.

Those filing electronically should refer to Pub. 5124 for instructions on how to populate the fields for the electronic Form 8966. These instructions can generally be used to supplement Pub. 5124. Information on how to submit the Form 8966 electronically to the IRS is provided in Pub. 5190 and Pub. 5188.

If you are required to file electronically but fail to do so, and you do not have an approved waiver on record, penalties under sections 6721 through 6724 may apply.

Where to file paper Form 8966.

If you have received a waiver of the Form 8966 electronic filing requirement from the IRS or are not otherwise required to file Form 8966 electronically, you may send all paper Forms 8966, along with Form 8966-C, Cover Sheet for Form 8966 Paper Submissions, to the following address.

Internal Revenue Service
FATCA, Stop 6052 AUSC
3651 South IH 35
Austin, Texas 78741

More information and updates to Form 8966.

For information about FATCA, including updates to Form 8966 and its instructions, as well as answers to Frequently Asked Questions, go to IRS.gov/FATCA.

Definitions

For detailed information about definitions that apply for purposes of FATCA generally, see Regulations section 1.1471-1(b). A Reporting Model 1 FFI or Reporting Model 2 FFI should also refer to definitions that may apply under an applicable IGA or apply pursuant to any applicable domestic law pertaining to its FATCA obligations. Solely for purposes of filing this Form 8966, the following definitions are provided to help guide filers through the process.

Account/financial account.

An account or financial account means a financial account described in Regulations section 1.1471-5(b).

Account holder.

An account holder is the person who holds a financial account, as determined under Regulations section 1.1471-5(a)(3).

Account maintained by a PFFI or Reporting Model 2 FFI.

An account maintained by a PFFI or Reporting Model 2 FFI means an account that a PFFI or Reporting Model 2 FFI is treated as maintaining under Regulations section 1.1471-5(b)(5).

Branch.

A branch means a unit, business, or office of a financial institution that is treated as a branch under the regulatory regime of a country or that is otherwise regulated under the laws of a country as separate from other offices, units, or branches of the financial institution, and includes a disregarded entity of a financial institution. A branch includes units, businesses, and offices of a financial institution located in the country (or jurisdiction) in which the financial institution is a resident as well as units, businesses, and offices of a financial institution located in the country in which the financial institution is created or organized. All units, businesses, or offices of a PFFI located in a single country (or jurisdiction), including all disregarded entities located in such single country (or jurisdiction), must be treated as a single branch.

Branch that maintains an account.

A branch, including a disregarded entity, maintains an account if the rights and obligations of the account holder and the FFI with regard to such account (including any assets held in the account) are governed by the laws of the country of the branch or disregarded entity.

Direct Reporting NFFE.

A Direct Reporting NFFE is an NFFE that has elected to report its substantial U.S. owners to the IRS pursuant to Regulations section 1.1472-1(c)(3).

Deemed-compliant FFI.

A deemed-compliant FFI means an FFI that is treated, pursuant to section 1471(b)(2) and Regulations section 1.1471-5(f), as meeting the requirements of section 1471(b).

Excepted NFFEs.

Excepted NFFEs include NFFEs that are QIs, WPs, and WTs, certain publicly traded corporations (including certain affiliates of such corporations), certain territory entities, active NFFEs, excepted nonfinancial entities, Direct Reporting NFFEs, and Sponsored Direct Reporting NFFEs as described in Regulations section 1.1472-1(c)(1).

Exempt beneficial owner.

An exempt beneficial owner is any person described in Regulations section 1.1471-6(b) through (g) and includes any person treated as an exempt beneficial owner under an applicable Model 1 IGA or Model 2 IGA.

Financial institution (FI).

An FI is any institution that is a depository institution, custodial institution, investment entity, insurance company (or holding company of an insurance company) that issues cash value insurance or annuity contracts, or a holding company or treasury center that is part of an expanded affiliated group of certain FFIs, and includes a financial institution as defined under an applicable Model 1 IGA or Model 2 IGA. See Regulations section 1.1471-5(e)(1).

Foreign financial institution (FFI).

Except as otherwise provided for certain foreign branches of a U.S. financial institution or Territory Financial Institution, an FFI means a financial institution that is a foreign entity. The term foreign financial institution also includes a foreign branch of a U.S. financial institution with a QI Agreement in effect.

Foreign reportable amount.

The term “foreign reportable amount” means the aggregate amount of foreign source payments described in Regulations section 1.1471-4(d)(4)(iv).

Global intermediary identification number (GIIN).

A GIIN is a number assigned to a PFFI, Reporting Model 1 FFI, Reporting Model 2 FFI, RDCFFI, and certain other registering entities (for example, a Direct Reporting NFFE). A separate GIIN will be issued to the FFI to identify, among other things, each jurisdiction where the FFI maintains a branch not treated as a limited branch. A Direct Reporting NFFE will be issued only one GIIN, irrespective of where it maintains branches.

Model 1 IGA.

A Model 1 IGA means an agreement between the United States or the Treasury Department and a foreign government or one or more foreign agencies to implement FATCA through reporting by financial institutions to such foreign government or agency thereof, followed by automatic exchange of the reported information with the IRS. For a list of jurisdictions treated as having an IGA in effect, see Treasury.gov/Policy-Issues/Tax-Policy/Foreign-Account-Tax-Compliance-Act.

Model 2 IGA.

A Model 2 IGA means an agreement or arrangement between the United States or the Treasury Department and a foreign government or one or more foreign agencies to implement FATCA through reporting by financial institutions directly to the IRS in accordance with the requirements of the FFI agreement, as modified by an applicable Model 2 IGA, supplemented by the exchange of information between such foreign government or agency thereof and the IRS. For a list of jurisdictions treated as having an IGA in effect, see Treasury.gov/Policy-Issues/Tax-Policy/Foreign-Account-Tax-Compliance-Act.

Non-consenting U.S. account.

For purposes of a Reporting Model 2 FFI, a non-consenting U.S. account shall have the meaning that it has under an applicable Model 2 IGA.

Non-financial foreign entity (NFFE).

A non-financial foreign entity (NFFE) is a foreign entity that is not a financial institution. An NFFE includes a territory NFFE as defined in Regulations section 1.1471-1(b)(132) and a foreign entity treated as an NFFE pursuant to a Model 1 IGA or Model 2 IGA.

Nonparticipating FFI.

A nonparticipating FFI is an FFI other than a PFFI, a deemed-compliant FFI, or an exempt beneficial owner.

Nonreporting FI.

A nonreporting FI means an entity that is resident in or established in a jurisdiction that has in effect a Model 1 IGA or Model 2 IGA and that is treated as a nonreporting FI in Annex II of the applicable Model 1 IGA or Model 2 IGA or that is otherwise treated as a deemed-compliant FFI or an exempt beneficial owner under Regulations sections 1.1471-5 or 1.1471-6.

Owner-documented FFI (ODFFI).

An ODFFI is an FFI described in Regulations section 1.1471-5(f)(3).

Participating FFI (PFFI).

A PFFI is an FFI that has agreed to comply with the requirements of an FFI agreement with respect to all branches of the FFI, other than a branch that is a reporting Model 1 FFI or a U.S. branch. The term PFFI also includes an FFI or branch of an FFI described in a Model 2 IGA that has agreed to comply with the requirements of an FFI agreement with respect to a branch, and a QI branch of a U.S. financial institution, unless such branch is a reporting Model 1 FFI.

Passive NFFE.

A passive NFFE is an NFFE that is not an excepted NFFE. With respect to a Reporting Model 2 FFI filing this Form 8966 to report its accounts and payees, a passive NFFE is an NFFE that is not an active NFFE (as defined in the applicable Model 2 IGA).

Pooled reporting.

For purposes of this form, a PFFI is permitted to report recalcitrant account holders (or, with respect to a Reporting Model 2 FFI, non-consenting U.S. accounts) on an aggregate basis in a reporting pool rather than report specific account holder information. With respect to recalcitrant account holders, a reporting pool consists of account holders that fall within a particular type described in Regulations section 1.1471-4(d)(6). With respect to non-consenting U.S. accounts, see Accounts and Withholdable Payments Required To Be Reported—Accounts for which pooled reporting is permitted, later.

Qualified Intermediary (QI), Withholding Foreign Partnership (WP), Withholding Foreign Trust (WT).

A QI is a foreign entity (or foreign branch of a U.S. financial institution) that has in effect a QI agreement with the IRS. A WP is a foreign partnership that has in effect a withholding foreign partnership agreement with the IRS. A WT is a foreign trust that has in effect a withholding foreign trust agreement with the IRS.

Recalcitrant account holder.

A recalcitrant account holder is an account holder (other than an account holder that is an FFI) of a PFFI or registered deemed-compliant FFI that has failed to provide the FFI maintaining its account with the information required under Regulations section 1.1471-5(g).

Registered deemed-compliant FFI (RDCFFI).

A registered deemed-compliant FFI is an FFI described in Regulations section 1.1471-5(f)(1), and includes a Reporting Model 1 FFI, a QI branch of a U.S. financial institution that is a Reporting Model 1 FFI, and a nonreporting FI treated as a registered deemed-compliant FFI under a Model 2 IGA.

Related entity or branch of a Reporting Model 2 FFI.

A related entity or branch of a Reporting Model 2 FFI is an entity or branch treated as a nonparticipating FFI under Article 3(5) of the Model 2 IGA (or any analogous provision in an applicable Model 2 IGA).

Reporting Model 1 FFI.

A Reporting Model 1 FFI is an FI, including a foreign branch of a U.S. financial institution, treated as a reporting financial institution under a Model 1 IGA.

Reporting Model 2 FFI.

A Reporting Model 2 FFI is an FI or branch of an FI treated as a reporting financial institution under a Model 2 IGA.

Specified U.S. person.

A specified U.S. person is any U.S. person described in Regulations section 1.1473-1(c).

Sponsored Direct Reporting NFFE.

A Sponsored Direct Reporting NFFE is a Direct Reporting NFFE that has a Sponsoring Entity perform due diligence and reporting requirements on behalf of the Sponsored Direct Reporting NFFE as described in Regulations section 1.1472-1(c)(5).

Sponsored FFI.

A Sponsored FFI is an FFI that is an investment entity, a controlled foreign corporation, or a closely held investment vehicle that has a Sponsoring Entity that performs certain due diligence, withholding, and reporting obligations on behalf of the Sponsored FFI.

Sponsoring Entity.

A Sponsoring Entity is an entity that has registered with the IRS to perform the due diligence, withholding, and reporting obligations of one or more Sponsored FFIs or Sponsored Direct Reporting NFFEs.

Substantial U.S. owner.

A substantial U.S. owner is a specified U.S. person described in Regulations section 1.1473-1(b). For purposes of filing this form, a Reporting Model 2 FFI reporting an account held by a passive NFFE should substitute the term “controlling person that is a specified U.S. person” for “substantial U.S. owner” and refer to the applicable Model 2 IGA for the definition of controlling person. A territory NFFE that is not an excepted NFFE determines its substantial U.S. owners by applying the 10% threshold in Regulations section 1.1473-1(b)(1).

Territory Financial Institution.

A Territory Financial Institution is a financial institution that is incorporated or organized under the laws of any U.S. territory, excluding a territory entity that is a financial institution only because it is an investment entity.

Territory Financial Institution treated as a U.S. person.

A Territory Financial Institution treated as a U.S. person means a Territory Financial Institution treated as a U.S. person under Regulations section 1.1471-3(a)(3)(iv).

Trustee-Documented Trust.

A Trustee-Documented Trust is a trust described as such in a Model 1 IGA or Model 2 IGA.

U.S. account.

A U.S. account is any account held by one or more specified U.S. persons. A U.S. account also includes any account held by a passive NFFE that has one or more substantial U.S. owners, or in the case of a Reporting Model 2 FFI, any account held by a passive NFFE that has one or more controlling persons that are specified U.S. persons. See Regulations section 1.1471-5(a) and an applicable Model 2 IGA.

U.S. branch treated as a U.S. person.

A U.S. branch treated as a U.S. person is a U.S. branch that is treated as a U.S. person under Regulations section 1.1441-1(b)(2)(iv)(A).

Withholding agent.

With respect to a withholdable payment, a withholding agent is a person described in Regulations section 1.1473-1(d).

Withholdable payment.

A withholdable payment is a payment described in Regulations section 1.1473-1(a).

Accounts and Withholdable Payments Required To Be Reported

Accounts to be reported.

A PFFI, Reporting Model 2 FFI, or RDCFFI required to report as if it is a PFFI must file a separate Form 8966 annually for each account required to be reported, or for each group of accounts for which pooled reporting is permitted, in accordance with the FFI agreement and Regulations section 1.1471-4(d). Such an FFI must report with respect to accounts required to be reported that are maintained at any time during each calendar year. This includes accounts that the FFI is required to treat as U.S. accounts or accounts held by ODFFIs, including accounts that are identified as U.S. accounts following a change in circumstances during such year or due to the expiration during such year of the time period provided in the applicable due diligence procedures for documenting the account holder. Such an FFI must also report accounts that are treated as held by recalcitrant account holders at the end of the calendar year. If an account holder rolls over the amounts in one account into another account (of the same or different type) with the same FFI during the calendar year, do not report the account twice. Form 8966 reporting is required for the following accounts.

  • U.S. account maintained by a PFFI, Reporting Model 2 FFI, or RDCFFI required to report as if it is a PFFI that is held by a specified U.S. person, and for each substantial U.S. owner (or, in the case of a Reporting Model 2 FFI, each controlling person that is a specified U.S. person) of a passive NFFE for which the FFI maintains the account. File a separate Form 8966 for each substantial U.S. owner (or controlling person) of a passive NFFE (as determined under the Regulations or an applicable Model 2 IGA) that is a specified U.S. person.

    Note.

    See Regulations section 1.1471-5(b) for details on the types of accounts potentially subject to reporting, including depository accounts, custodial accounts, equity or debt interests in certain types of financial institutions, and certain cash value insurance or annuity contracts. Exceptions are provided, including for individual deposit accounts with a balance or value less than $50,000 (unless an election is made to forego the exception) and for certain retirement and other accounts. See Regulations sections 1.1471-5(a)(4) and 1.1471-5(b)(2). Also see Regulations section 1.1471-5(a)(3) concerning who is considered the account holder where the listed holders are certain trusts or agents, or when an account is jointly held.

  • Account held by an ODFFI as defined in Regulations section 1.1471-5(f)(3). File a separate Form 8966 to report for each specified U.S. person that owns certain equity or debt interests in the ODFFI described in Regulations sections 1.1471-3(d)(6)(iv)(A)(1) and (2) and 1.1471-4(d)(2)(iii)(D) (excluding certain indirect owners described in Regulations section 1.1471-5(f)(3)(ii)(E)).

  • Account maintained by a Trustee-Documented Trust that is a nonreporting Model 2 FFI as defined in the applicable Model 2 IGA. The trustee files a Form 8966 to report each U.S. account (within the meaning of the Model 2 IGA) of the Trustee-Documented Trust.

  • Account held by a Territory Financial Institution not treated as a U.S. person. File a separate Form 8966 with respect to each specified U.S. person or substantial U.S. owner of a passive NFFE for which the Territory Financial Institution acts as an intermediary or is a flow-through entity and provides the PFFI (including a Reporting Model 2 FFI) with the information and documentation required under Regulations section 1.1471-3(c)(3)(iii)(G). See Regulations section 1.1471-4(d)(2)(ii)(B)(2).

  • Accounts for which pooled reporting is permitted. PFFIs may report accounts held by the following persons on a Form 8966 by pooled reporting type: recalcitrant account holders with U.S. indicia, recalcitrant account holders without U.S. indicia, recalcitrant account holders that are U.S. persons, recalcitrant account holders that are passive NFFEs, and recalcitrant account holders of dormant accounts. See Regulations section 1.1471-4(d)(6). A Reporting Model 2 FFI, under the terms of the Model 2 IGA, is required to report certain aggregate information regarding accounts it is required to treat as non-consenting U.S. accounts on Form 8966. If a Reporting Model 2 FFI is reporting a preexisting account that is a non-consenting U.S. account, the Reporting Model 2 FFI should use the pooled reporting category for recalcitrant account holders that are U.S. persons or recalcitrant account holders with U.S. indicia (if the Reporting Model 2 FFI treats the account as a U.S. account based on U.S. indicia as permitted under Annex I of the Model 2 IGA). If a Reporting Model 2 FFI is reporting a new individual account that has a change in circumstances that causes the Reporting Model 2 FFI to know or have reason to know that the original self-certification is incorrect or unreliable and the Reporting Model 2 FFI is unable to obtain a valid self-certification establishing whether the account holder is a U.S. citizen or resident, the Reporting Model 2 FFI should use the pooled reporting category for recalcitrant account holders with U.S. indicia. (See Specific Instructions, Part V, Pooled Reporting Type.)

Account information to be reported.

The following information is reported on Form 8966. See Specific Instructions, later, to determine the information you are required to report based on your filing status.

  • Account held by specified U.S. persons. Identification of the account holder (name, address, and U.S. TIN), account number, account balance or value, certain enumerated payments with respect to the account (described in Part IV), and such other information as may be required on Form 8966 or by these instructions. See Regulations section 1.1471-4(d)(3)(ii).

  • Account held by passive NFFE. With respect to a passive NFFE, on a separate Form 8966 for each substantial U.S. owner, the name and address of the NFFE, the identification of the substantial U.S. owner (name, address, and U.S. TIN), account number, account balance or value, certain enumerated payments with respect to the account (described in Part IV), and such other information as may be required on Form 8966 or by these instructions. See Regulations section 1.1471-4(d)(3)(iii).

  • Account held by ODFFI. With respect to an account held by an ODFFI, the name and address of the ODFFI and, with respect to each specified U.S. person that owns certain equity or debt interests in the ODFFI described in Regulations section 1.1471-3(d)(6)(iv)(A)(1) and (2) (excluding certain indirect owners described in Regulations section 1.1471-5(f)(3)(ii)(E)), identification of the specified U.S. person (name, address, and TIN), account number, account balance or value, certain enumerated payments with respect to the account (described in Part IV), and such other information as may be required on Form 8966 or by these instructions. A separate Form 8966 must be filed for each such specified U.S. person. See Regulations sections 1.1471-3(d)(6)(iv)(A)(1) and (2), and 1.1471-4(d)(3)(iv)(B).

  • Accounts held by recalcitrant account holders. Report the number of accounts included in the reporting pool and the aggregate account balance or value for such accounts.

Withholding Agent Reporting

A withholding agent (other than an FFI reporting accounts maintained by such FFI under the account reporting rules described earlier in Accounts and Withholdable Payments Required To Be Reported), files Form 8966 to report the following in connection with a withholdable payment.

  • Amounts paid to an ODFFI. With respect to each ODFFI payee, on a separate Form 8966 for each specified U.S. person that owns certain equity or debt interests in the ODFFI described in Regulations section 1.1471-3(d)(6)(iv)(A)(1) and (2) (excluding certain indirect owners described in Regulations section 1.1471-5(f)(3)(ii)(E)), identification of the ODFFI and specified U.S. person (name, address, and TIN), total of all withholdable payments made to the ODFFI, account balance or value, and such other information as may be required on Form 8966 or by these instructions. A withholding agent is not required to report on Form 8966 on a withholdable payment made to a PFFI (including a Reporting Model 2 FFI) or a Reporting Model 1 FFI that is allocated to a payee that is an ODFFI on an FFI withholding statement when the PFFI (including a Reporting Model 2 FFI) or Reporting Model 1 FFI includes on the statement the certification described in Regulations section 1.1471-3(c)(3)(iii)(B)(2)(v), provided that the withholding agent does not know or have reason to know that the certification is incorrect or unreliable. See Regulations section 1.1474-1(i)(2).

  • Amounts paid to a passive NFFE. With respect to a passive NFFE payee, on a separate Form 8966 for each specified U.S. person that is a substantial U.S. owner (or, in the case of a Reporting Model 2 FFI, controlling person), identification of the NFFE and each substantial U.S. owner (name, address, and TIN), total of all withholdable payments made to the NFFE, and such other information as may be required on Form 8966 or by these instructions. A withholding agent is not required to report on Form 8966 on a withholdable payment made to a PFFI (including a Reporting Model 2 FFI) or an RDCFFI that is allocated to a payee that is a passive NFFE with one or more substantial U.S. owners on an FFI withholding statement when the PFFI (including a Reporting Model 2 FFI) or RDCFFI includes on the statement the certification described in Regulations section 1.1471-3(c)(3)(iii)(B)(2)(iv), provided the withholding agent does not know or have reason to know that the certification is incorrect or unreliable. See Regulations section 1.1474-1(i)(1).

Specific Instructions

Before You Begin

There are five parts to Form 8966. A filer completes only the relevant parts of the form applicable for that filer, as set forth in the following chart.

Form 8966 Completion

FILER SEPARATE FORM 8966 FOR EACH COMPLETE PARTS
PFFI U.S. account held by a specified U.S. person I, II, and IV
  Substantial U.S. owner (or, in the case of a Reporting Model 2 FFI, controlling person) of a passive NFFE (passive NFFE is holder of the U.S. account) I, II, III, and IV
  Specified U.S. person owning certain equity or debt interests in an ODFFI for which you act as a designated withholding agent I, II, III, and IV
  Pooled reporting for recalcitrant account holders (or non-consenting U.S. accounts) I and V
WITHHOLDING AGENT Specified U.S. person owning certain equity or debt interests in an ODFFI to which the withholding agent makes a withholdable payment I, II, III, and IV
  Substantial U.S. owner of a passive NFFE to which the withholding agent makes a withholdable payment I, II, III, and IV
DIRECT REPORTING NFFE Substantial U.S. owner of a direct reporting NFFE I, III, and IV

Special instructions for filers not specifically listed in chart.

For purposes of applying the specific instructions (including this chart), a withholding agent includes a U.S. branch or Territory Financial Institution treated as a U.S. person. A Reporting Model 2 FFI files consistent with the requirements of a PFFI unless otherwise indicated. A Sponsoring Entity of a Sponsored FFI files under the requirements of a PFFI. A RDCFFI files under the requirements of a PFFI with respect to an account it is required to report as a condition of its deemed-compliant status. A trustee of a Trustee-Documented Trust files under the requirements of a PFFI. A Sponsoring Entity of a Sponsored Direct Reporting NFFE files under the requirements of a Direct Reporting NFFE. A related entity or branch described in an applicable Model 2 IGA, to the extent it is permitted to report, files under the requirements of a PFFI unless otherwise indicated. Entities filing consistent with a PFFI should substitute their chapter 4 status for PFFI where that term is used in the instructions, except as otherwise noted.

Amount and character of payments.

The amount and character of payments made with respect to an account may be determined under the same principles that the filer uses to report information on resident account holders to its domestic tax authority. Thus, the amount and character of items of income required to be reported need not be determined in accordance with U.S. federal tax principles. If any type of payment is not reported to domestic tax authorities, such amounts may be determined in the same manner as used for reporting to the account holder. Otherwise, reporting must either be in accordance with U.S. federal tax principles, or with any reasonable method consistent with the accounting principles applied by the PFFI. IRS consent is required to change such method, except that a change to rely on U.S. federal income tax principles is automatically permitted. See Regulations section 1.1471-4(d)(4)(iv)(E).

Currency translation.

Account balance or value, and any reportable payment, may be reported in U.S. dollars or in the currency in which the account or payment is denominated. In the case of an account, or payments denominated in multiple currencies, the filer may elect to report the account balance or value, or payments, in a currency in which the account or payments are denominated and is required to identify the currency, including the applicable currency code, in which the account is reported. See Regulations section 1.1471-4(d)(4)(iv)(B) and (F). If an account balance or payment is reported in U.S. dollars, the filer must calculate the amount in the manner described in Regulations section 1.1471-5(b)(4).

Rounding off to whole currency amounts.

You may round fractional currency amounts up (or down) to the closest non-fractional (whole) currency amount. If the fractional currency amount is equal to or greater than half the value of the basic currency unit, round up to the next whole currency amount. If the fractional currency amount is less than half the value of the basic currency unit, round down to the next whole currency amount. If you choose to round currency amounts, you must round all currency amounts reported.

The following illustrates the application of this rule to U.S. dollar amounts. To round off amounts to the nearest whole dollar, drop amounts under 50 cents and increase amounts from 50 to 99 cents to the next dollar. For example, $1.39 becomes $1 and $2.50 becomes $3. If you have to add two or more amounts to figure the amount to enter on a line, include cents (your fractional currency amount) when adding and only round off the total.

Correcting a previously filed Form 8966: Corrected, Amended, and Voided Reports.

If you are filing Form 8966 to correct or amend a previously filed Form 8966, submit the corrected information on the Form 8966 applicable to the year of the initial reporting as follows.

Corrected report.

If you are filing Form 8966 to correct information submitted to the IRS in a previously filed Form 8966 in response to an IRS notification, complete Form 8966 containing the corrected information as if it were the original Form 8966 for the year in question and check the box “Corrected report.” You do not need to include a copy of the originally filed Form 8966 marked “Voided report” with the corrected Form 8966.

This is an Image: caution.gifIf the Form 8966 that you are correcting was filed electronically with the IRS, then the corrected Form 8966 must also be filed electronically with the IRS. If the Form 8966 that you are correcting was filed in paper format with the IRS, then the corrected Form 8966 must also be filed in paper format with the IRS. Failure to follow this rule will result in your corrected Form 8966 not being processed by the IRS.

Amended report.

If you are filing Form 8966 to correct a previously filed Form 8966 and you have not been contacted by the IRS, complete Form 8966 containing the corrected information as if it were the original Form 8966 and check the box “Amended report.” A copy of the Form 8966 as originally filed with the IRS, updated by checking the “Voided report” box, must be filed with the amended Form 8966.

This is an Image: caution.gifIf the Form 8966 that you are amending was filed electronically with the IRS, then the amended Form 8966 and accompanying voided Form 8966 must be filed electronically with the IRS. If the Form 8966 that you are amending was filed in paper format with the IRS, then the amended Form 8966 and accompanying voided Form 8966 must be filed in paper format with the IRS. Failure to follow this rule will result in your amended Form 8966 not being processed by the IRS.

Voided report.

If you are filing an amended report, also file a copy of the Form 8966 as originally filed with the IRS, updated by checking the “Voided report” box.

No accounts to report.

A Direct Reporting NFFE or a Sponsoring Entity reporting on behalf of a Sponsored Direct Reporting NFFE that has no substantial U.S. owners to report during the calendar year should check this box and complete Part I only. This box is optional for filers other than Direct Reporting NFFEs and Sponsoring Entities filing on behalf of a Sponsored Direct Reporting NFFE.

Identifier.

Filers submitting paper Forms 8966 must assign a unique identifying number to each Form 8966 they file. The identifying number must be numeric (for example, 001) and must be exactly three digits. Enter the three-digit identifying number in the box for “Identifier” at the top of the form.

If you are filing a paper Form 8966 that is an amended, corrected, or voided report, you must include the unique identifying number that you assigned to the original form that is being amended, corrected, or voided. For example, to amend a form that had an identifying number of 002, the amended form should also have the identifying number 002. In addition, the identifying number will be used by the IRS to identify the form in any correspondence with the filer.

The identifying number must be unique to each original Form 8966 filed for the current year. The identifying number can be reused on a new original form in a subsequent year.

Part I—Identification of Filer

Use Part I to provide identifying information about the Form 8966 filer. All filers must complete lines 1a through 3c. Filers provide information on lines 4 through 10 as required by the specific instructions for those lines.

Line 1a.

Enter the filer’s name.

This is an Image: taxtip.gifA Direct Reporting NFFE must identify itself as the filer and provide its identifying information on lines 1a through 3c.

This is an Image: taxtip.gifA Sponsoring Entity or trustee that has agreed to assume the reporting obligations of a Sponsored FFI, a Sponsored Direct Reporting NFFE, or Trustee-Documented Trust, as applicable, must identify itself as the Form 8966 filer and must provide its identifying information on lines 1a through 3c. Sponsored FFIs, Sponsored Direct Reporting NFFEs, and Trustee-Documented Trusts are identified on line 6.

Line 1b.

Enter one of the filer category codes listed below.

This is an Image: taxtip.gifA related entity or branch should use the code for limited branch or limited FFI (code 03). All U.S. branches of FFIs not treated as U.S. persons should use the code for PFFIs (code 01). All U.S. branches that are treated as U.S. persons should use the code for withholding agents (code 10).

  • PFFI (other than a Reporting Model 2 FFI and including a U.S. branch of a PFFI not treated as a U.S. person)—Enter code 01.

  • RDCFFI—Enter code 02.

  • Limited Branch or Limited FFI—Enter code 03.

  • Reporting Model 2 FFI—Enter code 04.

  • QI, WP, or WT—Enter code 05.

  • Direct Reporting NFFE—Enter code 06.

  • Sponsoring Entity of a Sponsored FFI—Enter code 07.

  • Sponsoring Entity of a Sponsored Direct Reporting NFFE—Enter code 08.

  • Trustee of a Trustee-Documented Trust—Enter code 09.

  • Withholding Agent (including a U.S. branch of a PFFI, Reporting Model 1 FFI, Reporting Model 2 FFI, or RDCFFI treated as a U.S. person and a U.S. branch of a Reporting Model 1 FFI (including any other RDCFFI) or Limited FFI that is not treated as a U.S. person)—Enter code 10.

  • Territory Financial Institution treated as a U.S. person—Enter code 11.

Lines 2 through 3c.

Enter the filer’s mailing address, including country and postal code. If the filer is a PFFI, provide the mailing address of the office of the branch that maintains the account reported in Part II. If the filer’s post office does not deliver mail to a street address and the filer has a post office box, enter the filer’s post office box number instead of the filer’s street address.

Line 4.

If the filer has been assigned a GIIN by the IRS, enter it on line 4. Use the GIIN of the branch of an FFI that maintains the account (if applicable). If the filer is a Direct Reporting NFFE, enter its GIIN, regardless of whether or not the account is maintained by a branch. A Sponsoring Entity or trustee filing Form 8966 on behalf of a Sponsored FFI, Sponsored Direct Reporting NFFE, or Trustee-Documented Trust, as applicable, should enter the Sponsoring Entity’s or trustee’s GIIN.

This is an Image: taxtip.gifA Sponsoring Entity should enter its Sponsoring Entity’s GIIN, not a separate GIIN (if any) it receives when registering as a PFFI or RDCFFI. A trustee should enter the GIIN it receives when it registers to act as a trustee of a Trustee-Documented Trust, not a separate GIIN (if any) it receives when registering itself as a PFFI or RDCFFI.

Line 5.

If the filer has been assigned a U.S. taxpayer identification number (TIN) by the IRS, enter it on line 5. If you entered a GIIN on line 4, do not complete line 5. However, a QI, WP, or WT enters on line 5 the employer identification number (EIN) that was issued by the IRS to be used by the QI, WP, or WT when acting in its capacity as such (in addition to entering its GIIN on line 4). The filer is not required to obtain a U.S. TIN in order to file Form 8966 if the filer has not been issued a U.S. TIN. Do not enter a foreign TIN. If the filer does not have a U.S. TIN, leave this line blank.

Lines 6 through 10.

Lines 6 through 10 only need to be completed if the filer is a Sponsoring Entity or a trustee of a Trustee-Documented Trust, or if the filer is making a payment to a Territory Financial Institution that is acting as an intermediary or that is a flow-through entity and is not treated as a U.S. person or to a certified deemed-compliant FFI that is acting as an intermediary and providing the filer with information on a substantial U.S. owner of a passive NFFE account holder or payee.

Enter the information required by lines 6 through 10 to report the indicated information relating only to one of the following.

  • A Sponsored FFI on behalf of which a Sponsoring Entity is filing Form 8966.

  • A Sponsored Direct Reporting NFFE on behalf of which a Sponsoring Entity is filing Form 8966.

  • A Trustee-Documented Trust on behalf of which a trustee is filing Form 8966.

  • A Territory Financial Institution not treated as a U.S. person that is acting as an intermediary or that is a flow-through entity and that receives a withholdable payment from the filer of Form 8966.

  • A certified deemed-compliant FFI that is acting as an intermediary and providing the filer with information on a substantial U.S. owner of a passive NFFE account holder or payee.

Lines 6 through 8c.

Follow the instructions for lines 1a through 3c to provide the information required by lines 6 through 8c. Enter the name and mailing address, including country and postal code, of the Sponsored FFI, Sponsored Direct Reporting NFFE, Trustee-Documented Trust, Territory Financial Institution, or a certified deemed-compliant FFI acting as an intermediary. If the post office does not deliver mail to a street address and the entity identified on line 6 has a post office box, enter the post office box number instead of the street address.

Line 9.

If the entity reported on line 6 is a Sponsored FFI (other than a sponsored, closely held investment vehicle) or a Sponsored Direct Reporting NFFE, enter the Sponsored Entity’s GIIN on line 9. If the entity reported on line 6 is a Territory Financial Institution; Trustee-Documented Trust; Sponsored FFI that is a sponsored, closely held investment vehicle; or certified deemed-compliant FFI acting as an intermediary, leave this line blank.

This is an Image: caution.gifDo not enter the GIIN of the Sponsoring Entity or trustee of a Trustee-Documented Trust on line 9. That information is reported on line 4.

Line 10.

If the entity shown on line 6 has been issued a U.S. TIN, enter the TIN on line 10. If you entered the entity’s GIIN on line 9, do not complete line 10. If the entity shown on line 6 is a Territory Financial Institution that has not been issued a TIN by the IRS, report the EIN assigned to the entity by the relevant U.S. territory. If the entity shown on line 6 does not have either a GIIN or a TIN, leave line 10 blank.

Part II—Account Holder or Payee Information

See the chart at Specific Instructions and Special instructions for filers not specifically listed in chart, earlier, before you begin this part to determine whether you are required to complete Part II.

Direct Reporting NFFEs and Sponsored Direct Reporting NFFEs.

If you are a Direct Reporting NFFE or a Sponsoring Entity filing Form 8966 on behalf of a Sponsored Direct Reporting NFFE, do not complete Part II. Identifying information about the Direct Reporting NFFE or Sponsored Direct Reporting NFFE should be provided in Part I of the Form 8966.

This is an Image: caution.gifJointly held accounts. If you are reporting a jointly held account in Part II, you must report each account holder that is a specified U.S. person on a separate Form 8966.

Lines 1a through 5.

Account holder or payee information. Complete lines 1a through 5 as follows to report information with respect to:

  • A U.S. account held by a specified U.S. person and maintained by a PFFI.

  • A passive NFFE with substantial U.S. owners or an ODFFI with certain equity or debt interests held by specified U.S. persons that:

    1. Is an account holder of a PFFI; or

    2. Receives a withholdable payment from a withholding agent, unless the withholding agent receives the certification from a PFFI or RDCFFI receiving the payment, as described in Withholding Agent Reporting under Accounts and Withholdable Payments Required To Be Reported, earlier.

Line 1a.

Enter the name of the account holder or payee.

Line 1b.

Check the appropriate box to indicate whether the account holder or payee is an individual or entity.

Lines 2 through 3c.

Enter the account holder’s or payee’s residence address, including country and postal code, on lines 2 through 3c. If a residence address cannot be reported as required, report the address used for account or payee mailings by the FFI or withholding agent.

Line 3c.

If you are reporting an address in the United States, enter only the 9-digit ZIP code (ZIP + 4) for that address.

Line 4.

If the account holder or payee has been assigned a TIN, enter that number on line 4. If the account holder or payee does not have a TIN, leave line 4 blank.

Line 5.

Check the appropriate box on line 5 that describes the account holder or payee reported on line 1a.

Part III—Owner Information (File a Separate Report for Each U.S. Owner That Is a Specified U.S. Person)

See the chart at Specific Instructions and Special instructions for filers not specifically listed in chart, earlier, before you begin this part to determine whether you are required to complete Part III.

Use Part III to report information about substantial U.S. owners of a passive NFFE, substantial U.S. owners of a Direct Reporting NFFE, substantial U.S. owners of a Sponsored Direct Reporting NFFE, and specified U.S. persons owning certain equity or debt interests in an ODFFI identified in Part II, line 1a. Complete lines 1 through 4 to report U.S. owner information as follows.

Line 1.

Enter the U.S. owner’s name.

Lines 2 through 3c.

Enter the U.S. owner’s residence address, including country and postal code, on lines 2 through 3c.

Line 3c.

If you are reporting an address in the United States, enter only the 9-digit ZIP code (ZIP + 4) for that address.

Line 4.

Enter the social security number (SSN), individual taxpayer identification number (ITIN), or employer identification number (EIN) of the U.S. owner.

This is an Image: caution.gifU.S. owners. If you are a PFFI or withholding agent reporting substantial U.S. owners of a passive NFFE, or specified U.S. persons owning certain equity or debt interests in an ODFFI, you are required to file a separate Form 8966 to report information required in Part III for each such substantial U.S. owner or specified U.S. person. If you are a Direct Reporting NFFE or a Sponsoring Entity filing on behalf of a Sponsored Direct Reporting NFFE, you are required to file a separate Form 8966 to report each substantial U.S. owner.

Part IV—Financial Information

See the chart at Specific Instructions and Special instructions for filers not specifically listed in chart, earlier, before you begin this part to determine whether you are required to complete Part IV.

Use Part IV to provide financial information about:

  • An account maintained by a PFFI and held by a specified U.S. person, passive NFFE with substantial U.S. owners, or ODFFI with specified U.S. persons holding certain equity or debt interests in the ODFFI reported on Part II, line 1a.

  • A withholdable payment made to a passive NFFE with a substantial U.S. owner or an ODFFI with a specified U.S. person holding certain equity or debt interests in the ODFFI reported on Part II, line 1a, by a withholding agent that is not a PFFI.

  • The value of each substantial U.S. owner’s equity interest in the Direct Reporting NFFE or the Sponsored Direct Reporting NFFE.

  • The total of all payments made to each substantial U.S. owner of a Direct Reporting NFFE or a Sponsored Direct Reporting NFFE during the calendar year by such NFFE with respect to each such owner’s equity interest in the NFFE.

PFFI Filers

Enter the following information on lines 1 through 4d for each account required to be reported by a PFFI and held by a specified U.S. person, a passive NFFE with respect to its substantial U.S. owners, or an ODFFI with respect to certain equity or debt interests held by more than one specified U.S. person.

Line 1.

Enter the account number on line 1. The account number is the identifying number assigned by the PFFI for a purpose other than the filing of this form, or, if no such number is assigned to the account, a unique serial number or other number the PFFI assigns to the account for purposes of filing this form that distinguishes it from other accounts maintained by the PFFI. For example, the account number may be the account number of a custodial account or depository account, the code (ISIN or other) related to a debt or equity interest (if not held in a custody account), or the identification code of a cash value insurance contract or annuity contract. If the PFFI has no account numbering system, enter “NANUM” for no account number.

Line 2.

If the amounts reported on lines 3a and 4a through 4d are not reported in U.S. dollars, enter the code for the currency in which the amounts are reported. The currency code must be a valid three-character ISO 4217 currency code. If the amounts are reported in U.S. dollars, enter “USD.”

Line 3a.

Enter the average calendar year account balance or value if that amount is reported to the account holder. Otherwise, report the account balance or value as of the end of the calendar year. See Regulations section 1.1471-5(b)(4) for detailed rules for determining an account’s balance or value.

This is an Image: taxtip.gifIf an account is closed or transferred in its entirety during the calendar year, enter the amount or value withdrawn or transferred from the account in connection with the closure or transfer on line 3a and check the box on line 3b for “Account closed during the year.”

This is an Image: taxtip.gifEach holder of a jointly held account is attributed the entire balance or value of the joint account.

Line 3b. Account closed during the year.

Check this box if the account reported in Part IV was closed or transferred in its entirety during the calendar year. If an account holder rolls over the amounts in one account into another account (of the same or different type) with the same FFI during the calendar year, do not report the account as closed.

Line 4a.

Enter the aggregate gross amount of interest paid or credited to the account being reported for the calendar year.

Line 4b.

Enter the aggregate gross amount of dividends paid or credited with respect to an account being reported for the calendar year.

Line 4c.

Enter the aggregate gross proceeds from the sale or redemption of property paid or credited to the account being reported for the calendar year.

Line 4d.

Enter the aggregate gross amount of all income paid or credited to an account for the calendar year, reduced by interest, dividends, and gross proceeds reported on lines 4a through 4c. For accounts described in Regulations sections 1.1471-5(b)(1)(iii) (certain debt or equity interests, other than an interest as a partner in a partnership) or 1.1471-5(b)(1)(iv) (certain cash value insurance contracts and annuity contracts), enter the aggregate gross amounts paid or credited to the account during the calendar year, including payments in redemption (in whole or part) of the account, and do not enter any amounts on lines 4a through 4c. In the case of an account that is a partner’s interest in a partnership, report the amount of the partner’s distributive share of the partnership’s income or loss for the calendar year, without regard to whether any such amount is distributed to the partner during the year, and any guaranteed payments for the use of capital, and do not enter any amounts on lines 4a through 4c. The amounts required to be reported may be determined based on the partnership’s tax returns or, if the tax returns are unavailable by the due date for filing this form, the partnership’s financial statements or any other reasonable method used by the partnership for calculating the partner’s share of partnership income by such date.

This is an Image: taxtip.gifIf an account is closed or transferred in its entirety during a calendar year, report the amounts paid or credited to the account for the calendar year until the date of transfer or closure on lines 4a through 4d. See Regulations section 1.1471-4(d)(4)(iv)(D).

Withholding Agents

A withholding agent that is not an FFI should enter the following information on lines 1 through 4d in connection with withholdable payments made to:

  • An account maintained by the withholding agent and held by a passive NFFE with a substantial U.S. owner or an ODFFI with a specified U.S. person owning certain equity or debt interests in the ODFFI.

  • A payment on an obligation made to a payee that the withholding agent treats as a passive NFFE with substantial U.S. owner(s) or an ODFFI with a specified U.S. person owning certain equity or debt interests in the ODFFI.

Line 1.

If the payment is made to an account, enter the account number on line 1. If the payment is not made to an account maintained by the payor, enter “NANUM” for no account number.

Line 2.

If the amounts reported on lines 3a and 4a through 4d are not reported in U.S. dollars, enter the code for the currency in which the amounts are reported. The currency code must be a valid three-character ISO 4217 currency code. If the amounts are reported in U.S. dollars, enter “USD.”

Line 3a.

With respect to an account held by an ODFFI, enter the average calendar year account balance or value if that amount is reported to the account holder. Otherwise, report the account balance or value as of the end of the calendar year. See Regulations section 1.1471-5(b)(4) for detailed rules for determining an account’s balance or value. If the account holder is a passive NFFE, or if the payment is not made to an account, enter “0” on this line.

Line 3b.

Do not check the box on line 3b.

Line 4a.

Enter the aggregate gross amount of interest paid (or credited to the payee’s account) that is a withholdable payment for the calendar year.

Line 4b.

Enter the aggregate gross amount of dividends paid (or credited to the payee’s account) that is a withholdable payment for the calendar year.

Line 4c.

Enter the aggregate gross proceeds paid (or credited to the payee’s account) that is a withholdable payment for the calendar year.

Line 4d.

Enter the aggregate gross amount of all income paid (or credited to the payee’s account) that is a withholdable payment for the calendar year, reduced by interest, dividends, and gross proceeds reported on lines 4a through 4c.

Direct Reporting NFFEs and Sponsored Direct Reporting NFFEs

If you are a Direct Reporting NFFE or a Sponsoring Entity filing Form 8966 on behalf of a Sponsored Direct Reporting NFFE, complete lines 1 through 4d as follows.

Line 1.

Enter “NANUM” (for no account number) on line 1.

Line 2.

If the amounts reported on lines 3a and 4a through 4d are not reported in U.S. dollars, enter the code for the currency in which the amounts are reported. The currency code must be a valid three-character ISO 4217 currency code. If the amounts are reported in U.S. dollars, enter “USD.”

Line 3a.

Enter the value of the equity interest in the NFFE of the substantial U.S. owner identified in Part III.

Line 3b.

Do not check the box on line 3b.

Lines 4a through 4d.

Enter the total of all payments made by the NFFE during the calendar year to the substantial U.S. owner identified in Part III (either divided by type of payment on lines 4a through 4d or as one amount on line 4d), including the gross amounts paid or credited to the substantial U.S. owner with respect to such owner’s equity interest in the NFFE during the calendar year, which include payments in redemption or liquidation (in whole or part) of the substantial U.S. owner’s equity interest in the NFFE.

Part V—Pooled Reporting Type

See the chart at Specific Instructions and Special instructions for filers not specifically listed in chart, earlier, before you begin this part to determine whether you are required to complete Part V.

If you are a PFFI, use Part V to report information about the accounts held by recalcitrant account holders (or, for a Reporting Model 2 FFI, non-consenting U.S. accounts) on a pooled basis. If you are required to report more than one type of pooled reporting account, file a separate Form 8966 for each type.

This is an Image: caution.gifDirect Reporting NFFEs and Sponsored Direct Reporting NFFEs. Do not complete Part V.

Lines 1 through 5.

Complete lines 1, 2, 4, and 5 as follows to report information about accounts for which pooled reporting is permitted. Do not complete line 3.

Line 1.

Check the appropriate box for the applicable pooled reporting type. See Accounts and Withholdable Payments Required To Be Reported—Accounts for which pooled reporting is permitted for the categories of pooled reporting accounts.

This is an Image: taxtip.gifIf you are a Reporting Model 2 FFI reporting a preexisting account that is a non-consenting U.S. account, use the pooled reporting category for recalcitrant account holders that are U.S. persons or recalcitrant account holders with U.S. indicia (if the Reporting Model 2 FFI treats the account as a U.S. account based on U.S. indicia as permitted under Annex I of the Model 2 IGA). If you are a Reporting Model 2 FFI reporting a new individual account that has a change in circumstances that causes you to know or have reason to know that the original self-certification is incorrect or unreliable and you are unable to obtain a valid self-certification establishing whether the account holder is a U.S. citizen or resident, use the pooled reporting category for recalcitrant account holders with U.S. indicia.

Line 2.

Enter the total number of accounts reported in Part V.

Line 3.

Do not complete this line.

Line 4.

Enter the aggregate balance or value of the accounts held by recalcitrant account holders (or, for Reporting Model 2 FFIs, non-consenting U.S. accounts) at the end of the year.

Line 5.

If the amounts reported on lines 3 and 4 (to the extent applicable) are not reported in U.S. dollars, enter the code for the currency in which the amounts are reported. The currency code must be a valid three-character ISO 4217 currency code. If the amounts are reported in U.S. dollars, enter “USD.”

Instructions for Form 8966 — Notices

Paperwork Reduction Act Notice.

We ask for the information on this form to carry out the Internal Revenue laws of the United States. Chapter 4 of the Code requires certain withholding agents and foreign financial institutions to report information with respect to certain U.S. accounts, substantial U.S. owners of passive NFFEs, U.S. accounts held by owner-documented FFIs, and certain other accounts as applicable based on the filer’s chapter 4 status. Form 8966 is used to comply with this reporting requirement.

You are not required to provide the information requested on a form that is subject to the Paperwork Reduction Act unless the form displays a valid OMB control number. Books or records relating to a form or its instructions must be retained as long as their contents may become material in the administration of any Internal Revenue law. Generally, tax returns and return information are confidential, as required by section 6103.

The time needed to complete and file this form will vary depending on individual circumstances. The estimated average time is 25 minutes.

If you have comments concerning the accuracy of this time estimate or suggestions for making this form simpler, we would be happy to hear from you. You can send us comments from IRS.gov/FormComments. Or you can write to Internal Revenue Service, Tax Forms and Publications,1111 Constitution Ave. NW, IR-6526, Washington, DC 20224. Do not send the form to this address. Instead, see When, How, and Where To File, earlier.

The links below will take you to FAQs for each specific notification type. These notifications may be sent from the IRS after files have been processed by the IRS System, the International Compliance Management Model (ICMM). You can use the 3-letter code included in your error notification and in parentheses below to find the specific section relevant to your error notification.

  • Failed Download Notification (NDW)
  • Failed Decryption Notification (NDC)
  • Incorrect AES Key Size (NKS)
  • Failed Decompression Notification (NDP)
  • Failed Signature Check Notification (NSC)
  • Failed Threat Scan Notification (NTD)
  • Failed Virus Scan Notification (NVS)
  • Failed Schema Notification (NSV)
  • Invalid MessageRefId Notification (NMR)
  • Duplicate MessageRefId Notification (NDM)
  • Invalid DocRefld Notification (NDR)*
  • Interim Valid File Notification (NIM)
  • Certificate Failure Notification (NCF) (New as of March 2018)
  • Failed Decoding (NDF) (New as of March 2018)
  • Invalid File Format (NIF) (New as of March 2018)
  • If You Have Not Received Your ICMM Notification Within 24 hours
  • Request for Additional Extension of Time to File Form 8966
  • Request for Waiver from Filing Form 8966 Electronically
  • FATCA ICMM Notification and Record-level Errors
  • 1.1 FATCA Notification Code NTP: File Contains Test Data for Production Environment
  • 1.2 FATCA Notification Code NPT: File Contains Production Data for Test Environment
  • 1.3 FATCA Notification Code NVF: Valid File Notification (With Record-Level Errors)
  • 1.4 ICMM Record-level Error Notifications for Paper Forms 8966
  • 1.5 ICMM Paper Pooled Report Error Notification for Paper Forms 8966
  • 1.6 ICMM Paper Pooled Error Notification for Paper Forms 8966
  • ICMM TIN
  • Additional Resources and Support
  • Pre and Post Transmission Related Questions
  • Additional Support

Failed Download Notification (NDW)

Q1. Why did my organization receive this notification?

The IRS could not download the transmission with the IDES file ID, transmission ID and timestamp. Even though you successfully uploaded the transmission, it could not be downloaded before the seven day IDES retention period expired.

Q2. What could have prevented the IRS from downloading this transmission?

The IRS automatically downloads transmissions from IDES after receiving an alert from IDES that a transmission is available for download. A system failure or outage on either side of the IRS-IDES connection led to the failure to download.

Q3. What do I need to do as a result of this notification?

You will need to upload the transmission referenced by the listed IDES Sender’s File ID and IDES Transmission ID in the error notification again. Please ensure that the IRS encryption key you used for the initial transmission has not changed. If it has, please re-encrypt the plain text version of the file you are sending with the new IRS key, and upload this new encrypted transmission to IDES. The IRS will receive notification when the transmission is available and will download it at that time. The IRS will send another notification to you through IDES once your file has been downloaded and processed further.

Q4. Why can’t the IRS download the transmission now?

IDES automatically deletes transmissions that are not downloaded within seven days of upload. Additionally, once the download of a transmission is initiated by IRS, IDES will automatically delete the transmission in 24 hours. As a result of one of these automated deletions, your transmission is no longer available on IDES. You must upload the transmission to IDES again to satisfy FATCA requirements. Please refer to the IDES User GuidePDF, available on the IRS IDES Home, if you have any questions on how to prepare and upload transmissions to IDES. The IRS will be notified by IDES when your transmission is available, and will download it at that time.

Q5. Was there a problem with the contents of my file?

The IRS was not able to process your file therefore the records within the file could not be processed. Once the IRS has successfully downloaded your transmission from IDES, the file will be processed and you will be notified of the results, including whether the file was successfully processed or if any additional errors were identified.

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Failed Decryption Notification (NDC)

Q1. Why did my organization receive this notification?

The IRS could not decrypt the file with the IDES file ID, transmission ID and timestamp after downloading it from IDES. There are three situations that may have occurred:
a) the AES key provided with the file was not the same as the AES key used to encrypt the payload
b) the AES key used to encrypt is of the wrong type/wrong size, or it is missing completely
c) the public IRS key used to encrypt the AES key was not valid
d) the payload and/or encrypted AES key file was changed or modified after encryption

Q2. Which specific decryption step failed?

For security reasons the IRS does not disclose which situation caused the decryption failure.

Q3. What do I need to do as a result of this notification?

First, make sure you have the valid IRS public encryption key on your system, downloaded from IDES. Next, please encrypt the digitally-signed and compressed payload of the referenced file with a new AES key and then encrypt the new AES key with the valid IRS public key. Insert the re-encrypted payload and AES key files and a new XML header in an archive to create the IDES transmission. Finally, upload the transmission to IDES following all additional procedures (see IDES User GuidePDF, available on the IRS IDES Home) for transmission preparation and upload. The IRS will send another notification to you through IDES once your file has been downloaded and processed further.

Q4. What key should I use to encrypt my files?

Please follow the procedures in the IDES User GuidePDF, available on the IRS IDES Home, and your local encryption software to generate a unique, one-time use AES-256 key. You should be using this unique, one-time use AES-256 key to encrypt your payload and the valid IRS public key available on IDES to encrypt the AES key.

Q5. How do I determine if the IRS public key I am using is the correct version?

The valid IRS key is available on IDES. Please visit International Data Exchange Service for additional information and instructions on how to find and download the IRS public key for encrypting the AES key for transmission.

Q6. How do I download the valid public key for the IRS?

Please see the IDES User GuidePDF, available on the IRS IDES Home, for additional information and instructions on how to find and download the IRS public key for encrypting the AES key for transmission to the IRS. Also, please consult the documentation for your encryption software application for assistance in importing the IRS public key into your system after downloading.

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Incorrect AES Key Size (NKS)

Q1. Why did my organization receive this notification?

The IRS could not decrypt the referenced file because the size of AES key file was incorrect. The IRS expects a 48 byte AES key file, consisting of a 32 byte (256 bit) key and 16 byte (128 bit) initialization vector combined in a 48 byte encrypted file. Please do not submit a request to correct, amend or void any of the records in this file until you receive a notification that this file has been received as valid. For more information on this notification, including the classification of a failed file decryption under an intergovernmental agreement (IGA), please see: IRS FATCA ICMM Report Notifications Page. For more information on formatting the AES key file, please consult the IDES User GuidePDF.

Added: 01-17-17

Q2. Which specific decryption step failed?

This notification indicates an issue specifically with the AES key file size. You may not be using the CBC cipher, required as of July 11, 2016 or the AES key file size may be incorrect for another reason.

Added: 01-17-17

Q3. What key should I use to encrypt my files?

Please follow the procedures in the IDES User Guide, available on the IRS IDES Homepage, and your local encryption software to generate a unique, one-time use AES-256 key with CBC ciphering. You should be using this unique, one-time use AES-256 key to encrypt your payload and the valid IRS public key available on IDES to encrypt the AES key. Ensure that your 16-byte initialization vector is included with your AES key in the encrypted key file.

Added: 01-17-17

Q4. How do I ensure I am using the right encryption method?

Please refer to the IDES User Guide, available on the IRS IDES Homepage, and your local encryption software for specific instructions on using the AES-256-CBC encryption process.

Added: 01-17-17

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Failed Decompression Notification (NDP)

Q1. Why did my organization receive this notification?

The IRS could not decompress the file with the IDES file ID, transmission ID and timestamp after download from IDES. This failure occurred either because the file was compressed using an unsupported compression tool/algorithm, one or more files in the transmission are missing compression (not zipped), or because the file became corrupted after compression but before the AES encryption step.

Q2. What do I need to do as a result of this notification?

Please recompress the digitally signed XML file using a supported compression tool, and create a new IDES transmission with this file, following all procedures (see the IDES User GuidePDF, available on the IRS IDES Home) for IDES transmission preparation and upload. The IRS will send another notification to you through IDES once your file has been downloaded and processed further.

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Failed Signature Check Notification (NSC)

Q1. Why did my organization receive this notification?

The IRS could not validate the digital signature on the payload file with the IDES file ID, transmission ID and timestamp, with your organization’s valid public key on IDES.

Q2. What do I need to do as a result of this notification?

Please re-sign the file using the procedures provided in the IDES User GuidePDF, available on the IRS IDES Home, and your local encryption software package and recreate and upload the transmission to IDES following all procedures (see the IDES User Guide, available on the IRS IDES Home) for transmission preparation and upload. The IRS will send another notification to you through IDES once your file has been downloaded and processed further.

Q3. How do I digitally sign the file?

Please follow the procedures for your local encryption software and for IDES. See the IDES User GuidePDF, available on the IRS IDES Home, and your local encryption software for instructions on how to apply the digital signature.

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Failed Threat Scan Notification (NTD)

Q1. Why did my organization receive this notification?

The IRS detected one or more security threats embedded in the decrypted version of the payload and/or Sender Metadata files. The IRS cannot accept files with embedded security threats

Q2. What threat did the IRS detect?

For security reasons the IRS does not disclose specific threats identified on electronic communications received from third parties, or what is used to identify these threats. However, these threats can include items such as:

  • hyperlinks embedded within received files
  • JavaScript components
  • executable files (e.g., .exe files)
  • compressed archive files
  • prohibited characters (Apostrophe (‘), Double Quote («)

These items should not be part of any submitted file.

Note that the Apostrophe (‘) and Double Quote («) characters are prohibited by IRS as they could pose a security threat. (For a full list of character restrictions, see FATCA XML Schema Best Practices for Form 8966). As these characters would not be detected by an antivirus product, you will need to take other measure to ensure these characters are not present in any of your files.

Q3. What do I need to do as a result of this notification?

Please remove all prohibited characters from the payload and Sender Metadata files, then rebuild the full transmission for this payload file by following all procedures (see the IDES User GuidePDF, available on the IRS IDES Home) and scanning for viruses and other security threats with up-to-date antivirus software at each step in the process (digital signature, compression, encryption of the payload and AES key files, creation of the IDES metadata file, creation of the full transmission files) and upload the full transmission to IDES. The IRS will send another notification to you through IDES once your file has been downloaded and processed further.

Q4. What antivirus product should I use to clean my file?

Generally, any up-to-date and widely accepted antivirus software product should be capable of finding any other threat that the IRS detected. The IRS uses such products for virus and threat detection and removal. However, the IRS does not recommend the use of any particular product for this purpose. Prohibited characters will not be detected by an antivirus product; you will need to take other measures (e.g., a text editor) to ensure these characters are not present in any of your files.

Q5. What should I do if I need help with scanning my file for threats?

It is the sender’s responsibility to ensure all files are virus and threat free and comply with all IRS requirements and restrictions. Please contact your local IT support staff for assistance with this step, or consult the IDES User Guide and documentation provided by your antivirus software provider.

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Failed Virus Scan Notification (NVS)

Q1. Why did my organization receive this notification?

The IRS detected one or more computer viruses embedded in the decrypted version of the file. The IRS cannot accept a file with viruses present.

Q2. What virus did the IRS detect?

For security reasons the IRS does not disclose specific viruses identified on electronic communications received from third parties, or what is used to identify viruses. However, the viruses the IRS detects are typically found by up-to-date commercial anti-virus products.

Q3. What do I need to do as a result of this notification?

Please rebuild the full transmission for this payload file by following all procedures (see the IDES User GuidePDF, available on the IRS IDES Home) and scanning for viruses and other security threats with up-to-date antivirus software at each step in the process (digital signature, compression, encryption of the payload and AES key files, creation of the IDES metadata file, creation of the full transmission files), then upload the full transmission to IDES. The IRS will send another notification to you through IDES once your file has been downloaded and processed further.

Q4. What antivirus product should I use to clean my file?

Generally, any up-to-date and widely accepted antivirus software product should be capable of finding the virus that the IRS detected. The IRS uses such products for virus and threat detection and removal. However, the IRS does not recommend the use of a particular product for this purpose.

Q5. What should I do if I need help with scanning my file for viruses?

It is the sender’s responsibility to provide clean files, and to ensure all files are virus and threat free. Please contact your local IT support staff for assistance with this step, or consult the documentation provided by your antivirus software provider.

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Failed Schema Notification (NSV)

Q1. Why did my organization receive this notification?

The referenced file has one or more XML schema validation errors.

Q3. Are there any characters that are not allowed due to XML syntax rules and should be avoided in submitted XML documents?

Use of the ampersand (&) and less than (<) symbols are prohibited as they are not allowed by XML syntax rules and will cause the transmission to be rejected with a failed schema error notification. These symbols must be replaced with entity references.

Substituting any ampersand symbols with «&amp;» and less than symbols with «&lt;» in XML files will prevent the generation of the error notification.

Q4. Is there any namespace or element-specific XML guidance?

The IRS is currently mandating that users do not use default namespaces, but use namespace prefixes for all elements. This guidance is temporary and the restriction will be lifted in the coming weeks.

Q5. What do I need to do as a result of this notification?

Please verify the presence of prefixes for all elements in the referenced file, then revalidate the referenced file against the current version of the FATCA XML Schema (IRS Publication 5124 available at FATCA XML Schema) to identify and resolve the specific validation issue. Use this inspected file to recreate an IDES transmission and upload to IDES following all procedures (see the IDES User GuidePDF, available on the IRS IDES Home) for transmission preparation and upload. The IRS will send another notification to you through IDES once your file has been downloaded and processed further.

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Invalid MessageRefId Notification (NMR)

Q1. Why did my organization receive this notification?

The MessageRefId schema field in the referenced file consists of one or more blank characters or exceeds 200 characters in length. This field should be a unique identifier for a report file and is required to be at least one, but not more than 200, alphanumeric characters and cannot be all blank characters.

Updated: 03-03-16

Q2. Why was this issue not identified by my XML validation tool?

The FATCA XML User Guide (IRS Publication 5124 available at FATCA XML Schema) states that the MessageRefId should be a unique identifying number (created by the sender) that identifies the particular message being sent. Although a MessageRefId consisting of all blanks is valid against the schema, the IRS does not consider a blank MessageRefId to be unique. Furthermore, the IRS has limited the MessageRefId and DocRefId fields to 200 characters. The IRS requires non-blank MessageRefIds and DocRefIds that are no more than 200 characters in length in order to be able to accept your file.

Updated: 04-11-17

Q3. What do I need to do as a result of this notification?

Please correct the file by including a unique, valid alphanumeric character string in the MessageRefId field (see the FATCA XML User Guide, IRS Publication 5124 available at FATCA XML Schema) that does not consist of all blanks and that is no more than 200 characters in length. Use this file to recreate an IDES transmission and upload to IDES following all procedures (see the IDES User GuidePDF, available on the IRS IDES Home) for transmission preparation and upload. The IRS will send another notification to you through IDES once your file has been downloaded and processed further.

Updated: 04-11-17

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Duplicate MessageRefId Notification (NDM)

Q1. Why did my organization receive this notification?

The MessageRefId schema field in the submitted file is duplicative of another file you have submitted. This field should be a unique identifying number for a report file and is required to be a string of at least one alphanumeric character.

Updated: 03-03-16

Q2. Why was this issue not identified by my XML validation tool?

While your file is in the valid XML format, comparison of MessageRefIds takes place outside of XML validation. FATCA XML User Guide (IRS Publication 5124 available at FATCA XML Schema) states that the MessageRefId should be a unique identifying alphanumeric value (created by the sender) that identifies the particular message being sent. The IRS cannot accept more than one file from the same sender with the same MessageRefId.

Updated: 04-11-17

Q3. What do I need to do as a result of this notification?

Please correct the file by including a unique, valid alphanumeric character string in the MessageRefId field (see the FATCA XML User Guide, IRS Publication 5124 available at FATCA XML Schema) that does not consist of all blanks and does not exceed 200 characters in length. Use this file to recreate an IDES transmission and upload to IDES following all procedures (see the IDES User GuidePDF, available on the IRS IDES Home) for transmission preparation and upload. The IRS will send another notification to you through IDES once your file has been downloaded and processed further.

Updated: 04-11-17

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Invalid DocRefld Notification (NDR)*

*NoteAs of March 24, 2018, the IRS is no longer issuing this notification.  Any Invalid or duplicative DocRefIDs will result in an NVF with a record-level error rather than a file-level error.

Q1. Why did my organization receive this notification?

One or more records with DocRefId schema fields in the submitted file consist of one or more blank characters or exceed 200 characters in length. This field should contain the unique identifier of the specific account or pooled report it references and is required to be at least one, but not more than 200, alphanumeric characters, and cannot be all-blank characters.

Updated: 03-24-18

Q2. Why was this issue not identified by my XML validation tool?

The FATCA XML User Guide (IRS Publication 5124 available at FATCA XML Schema) states that the DocRefId data element should contain the unique identifier of the specific account or pooled report it references. Although a DocRefId consisting of all blanks is valid against the schema, the IRS does not consider a blank DocRefId to be unique. Furthermore, the IRS has limited the MessageRefId and DocRefId fields to 200 characters. The IRS requires non-blank MessageRefIds and DocRefIds that are no more than 200 characters in length in order to be able to accept your file.

Updated: 04-11-17

Q3. What do I need to do as a result of this notification?

Please correct the file by including a valid alphanumeric character string in all DocRefId fields per the FATCA XML Schema User Guide (IRS Publication 5124 available at FATCA XML Schema) that does not consist of all blanks and that is no more than 200 characters in length. Use this file to recreate an IDES transmission and upload to IDES following all procedures (see the IDES User GuidePDF, available on the IRS IDES Home) for transmission preparation and upload. The IRS will send another notification to you through IDES once your file has been downloaded and processed further.

Updated: 04-11-17

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Interim Valid File Notification (NIM)

*Note:  This notification was only applicable for files submitted in early 2015.  Filers should no longer be receiving this notification.

Q1. Why did my organization receive this notification?

The IRS has received and successfully completed the first phase of processing your file. At this time, there is no action for you to take with respect to this notification. Individual records in this file will be processed further at a later date, and you will be notified if any errors are encountered and if you need to take any further action.

Updated: 03-24-18

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Certificate Failure Notification (NCF) (New as of March 2018)

Q1. Why did my organization receive this notification?

Your certificate posted to IDES was not valid. The IRS cannot download a file from IDES if the transmitter certificate is not valid.

Added: 03-24-18

Q2. What do I need to do as a result of this notification?

Please post a valid certificate to IDES. Then re-encrypt the FATCA XML file with a new AES key. Re-package and resubmit the payload file to IDES using the new valid certificate.

Added: 03-24-18

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Failed Decoding (NDF) (New as of March 2018)

Q1. Why did my organization receive this notification?

The IRS could not download the referenced file that had been posted to IDES. The file could not be decoded because the encoding mechanism used did not match what was listed in the IDES metadata.

Added: 03-24-18

Q2. What kind of file encoding schemas are supported by the IRS?

The file encoding schema supported by the IRS is Base64.

Added: 03-24-18

Q3. What do I need to do as a result of this notification?

Ensure the file encoding is valid. Currently the IRS only supports Base 64 file encoding for transmission through IDES. Re-encrypt the payload and repost the file to IDES. The IRS will send another notification to you through IDES after we have downloaded and processed your file further.

Added: 03-24-18

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Invalid File Format (NIF) (New as of March 2018)

Q1. Why did my organization receive this notification?

The IRS could not download the referenced file that had been posted to IDES. Your specified file format type and actual file contents were inconsistent.

Added: 03-24-18

Q2. What kind of file formats are supported by the IRS?

The IRS supports 5 file formats:

File Type Binary Encoding Type
XML NONE
PDF Base64
TXT NONE
RTF Base64
JPG Base64

Added: 03-24-18

Q3. What do I need to do as a result of this notification?

Ensure the specified file format type and actual file contents are consistent and repost the file to IDES. Ensure the specified file format is one of the approved types that can be sent to the IRS. Ensure the file type included in the IDES metadata is consistent with the file type of the enclosed notification.

Added: 03-24-18

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If You Have Not Received Your ICMM Notification Within 24 hours

Q1. I uploaded a FATCA Report to IDES 3 days ago. I received an Alert from IDES via e-mail that my file was successfully uploaded, but I have not received a Notification back from the IRS about the status of my FATCA Report. What could be wrong?

The IDES alert of a successful upload is information about the transmission of your file. IDES alerts cannot provide information about the receipt and processing of your files by IRS ICMM. The IRS should issue an ICMM Notification for every FATCA Report that is successfully transmitted through IDES letting you know the status of your FATCA Report. You should always receive a Notification within 24 hours, and in most cases within a few minutes, of the IRS ICMM system receiving your file. However, the IRS has identified specific instances during testing where ICMM Notifications are not issued to filers when certain errors are present. In addition, the IRS has identified circumstances in which filers did not download their notifications before the 7 day retention period expired, and these notifications were deleted and are no longer available for download. The IRS is working to address and resolve these issues.

In the meantime, there are a few things you can do to maximize your ability to receive notifications sent to you, and to determine whether a notification has been sent to in response to your file. These are as follow:

  • First, make sure that e-mail alerts from IDES are not blocked as SPAM by your own e-mail system. Your e-mail system may have deleted it or may have sent it to you SPAM inbox. If you have been sent an alert that a notification is present, but the alert email is blocked you may never be aware of the notification’s availability for download.
  • Second, make sure your IDES User Profile is configured to allow IDES to send you e-mails, including alerts regarding notifications. There is a box that can be set to either send or not send you an e-mail notification. If you would like to receive and e-mail notification make sure it is set to send e-mail notification.
  • Third, check your IDES inbox over the next 24 hours following the upload of your file to IDES to determine whether there is a Notification waiting for download. Even if you have not received an e-mail Alert, the Notification could still be in your folder ready for download. After seven days the notification will automatically be deleted from the system.

If you have checked your folder in IDES and there is no Notification present after 48 hours or longer since your file was uploaded successfully, an error types which is suppressing a notification from being sent may have been detected on your file. A few things to check that may help include the following:

  • Making sure the digital certificate you are using for signature and encryption for FATCA data has not expired or been revoked by your Certificate Authority.
  • Also, you should double check the Metadata XML file that is part of your data packet, to ensure all of the mandatory data elements are correct. In particular, please make sure that FATCAEntCommunicationTypeCd is set to “RPT”, and that the TaxYear is set to “2014.”
  • Make sure all of the entries are correct. Did you indicate you were submitting a FATCA Report? Did you select the correct tax reporting year (it should be 2014)? Etc.

Once you’ve checked these items, you should resubmit your file.

Q2. What if I have mistakenly submitted my FATCA Report production files to the FATCA Report test environment?

It is possible that you submitted your FATCA Report production files to the FATCA Report test environment instead of to the FATCA Report production environment. Any production files that are submitted to the test environment will not be processed and will need to be re-submitted to the production environment. Please do not submit production files to the test environment. In addition, please do not submit test files to the production environment.

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Request for Additional Extension of Time to File Form 8966

Q1. How do I submit a request for additional extension of time to file Forms 8966?

Form 8809-IPDF needs to be submitted. Please follow the instructions for that form.

Updated: 03-24-18

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Request for Waiver from Filing Form 8966 Electronically

Q1. How do I submit a request to waive the requirement to file Forms 8966 electronically?

Form 8508-IPDF needs to be submitted. Please follow the instructions for that form.

Updated: 03-01-18

FATCA ICMM Notification and Record-level Errors

1.1 FATCA Notification Code NTP: File Contains Test Data for Production Environment

Q1. Do I need to void or correct this record?

Since this data is considered to be test data, and the IRS discourages submission of test data in its production environments, no further action should be taken with respect to this record. Please do not attempt to void, correct, or amend this record with additional test data. However, if you determine that the record is a valid record please resubmit with the proper DocTypeIndic value through IDES to the ICMM production environment.

Added: 09-14-15

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1.2 FATCA Notification Code NPT: File Contains Production Data for Test Environment

Q2. Do I need to void or correct this record?

This record does not need to be voided or otherwise modified in the test environment. If the records are valid production submissions, please submit through IDES to the ICMM production environment.

Added: 09-14-15

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1.3 FATCA Notification Code NVF: Valid File Notification (With Record-Level Errors)

Q3. What does this notification mean?

The IRS has received and successfully completed processing of your file. At this time, one or more record-level errors have been identified in your file and require correction. You will need to correct all identified record-level errors and resubmit the file.

Added: 09-14-15

Q4. Why weren’t these errors identified by my XML validation tool?

It is possible for a FATCA XML file to validate against the FATCA Intergovernmental Schema while not complying with FATCA reporting requirements. The FATCA XML V1.1 User Guide (IRS Publication 5124) details rules for FATCA data elements needed to validate against the FATCA schema, as well as mandatory data elements and values which extend beyond validation but are needed to satisfy reporting requirements.

Added: 09-14-15

Q5. Which record contained the detected errors?

The record indicated by the DocRefId value included with the error descriptions in the notifications is the record that must be corrected and resubmitted.

Updated: 03-03-16

Q6. Do I need to resubmit the entire file or just the corrected record?

Only the record with the corrected data needs to be resubmitted. However, since the record must be transmitted in a valid FATCA Report file, the full file must have sufficient data from the original file to pass XML validation and other checks, as defined in IRS Publication 5124PDF (pdf 1.59MB), including MessageSpec and Reporting FI data elements. In addition, the following changes from the original file are necessary:

  • The DocTypeIndCd value should be “FATCA2” for corrected data
  • The MessageRefId and DocRefId values for the file being corrected must be provided in the CorrMessageRefId and CorrDocRefId fields for the submitted file.

Updated: 03-03-16

Q7. What triggers a “TIN not in IRS specified format” error message?

The “TIN not in IRS specified format” error is generated when a non-GIIN value for a TIN data element is not in a valid format for a U.S. TIN. A value for a TIN data element must be either in a GIIN format or in one of the following formats for a U.S. TIN to be considered valid when filed:

  • Nine consecutive numerical digits without hyphens or other separators (e.g., “123456789”)
  • Nine numerical digits with two hyphens, one hyphen entered after the third numeric digit and a second hyphen entered after the fifth numeric digit (e.g., “123-45-6789”)
  • Nine numerical digits with a hyphen entered after the second digit (e.g., “12-3456789”)

If a filer has confirmed that the Account Holder is not required to have a US TIN in the agreed upon format then the filer does not need to re-file to correct this specific error. Any other errors included in the notification must be corrected and the filer should re-submit a corrected file for those errors only. The Account Holder TIN must be provided and cannot be blank characters in the TIN data sub-element.

Updated: 03-24-18

Q7a. What triggers a “TIN not in IRS specified format, contains only one character repeated” error message?

The “TIN not in IRS specified format, contains only one character repeated» error is generated when a US TIN is in one of the valid formats specified in Q7 above, but consists of nine digits that are all the same (ex. 555555555, 111-11-1111, 33-333333) or when a non-US TIN, which does not have to conform to the formats specified in Q7, consists of digits or characters that are all the same (ex. 9999999, XXXXXXX). A valid TIN will not consist only of one repeated character, regardless of country of origin.

If a filer has confirmed that the Account Holder is not required to have a US TIN in the agreed upon format then the filer does not need to re-file to correct this specific error. Any other errors included in the notification must be corrected and the filer should re-submit a corrected file for those errors only. The Account Holder TIN must be provided and cannot be blank characters in the TIN data sub-element.

Updated: 03-24-18

Q7b. What triggers a “TIN not in IRS specified format, contains non-numeric characters,” error message?

The “TIN not in IRS specified format, contains non-numeric characters» error is generated when a US TIN is in one of the valid formats specified in Q7 above, but includes any characters other than numeric digits (1-9) or «-» in the positions specified in Q7. A valid US TIN will not include any non-numeric characters.

If a filer has confirmed that the Account Holder is not required to have a US TIN in the agreed upon format then the filer does not need to re-file to correct this specific error. Any other errors included in the notification must be corrected and the filer should re-submit a corrected file for those errors only. The Account Holder TIN must be provided and cannot be blank characters in the TIN data sub-element.

Updated: 03-24-18

Q8. I have verified that the US TIN (in SSN or EIN form) for my reporting FI, intermediary, account holder, or substantial owner is correct; why am I getting the “TIN not in IR specified format” error?

Though the nine digits in the US TIN you have provided are the correct TIN for the person or entity being documented, you may have used an incorrect format for the TIN. Please see Question 7 above for the correct formats to be used for US TINs in FATCA reporting.

Updated: 03-24-18

Q9a.We received a record-level error of 8021 indicating an “Invalid DocRefID”, but do not see any formatting issue with the Account, Pooled, or Nil Report DocRefID. Why are we receiving this error?

Each record will be associated with a report-level DocRefID (Account, Pooled or Nil Report DocRefID) as well as one or more organization-level DocRefIDs (ReportingFI DocRefID, Intermediary DocRefID, and/or Sponsor DocRefID). If any of these DocRefIDs do not follow the DocRefID formatting requirements (see FATCA XML Schemas Best Practices for Form 8966 DocRefId), you will receive an “Invalid DocRefID” error. All DocRefIDs in the record should be checked to ensure they follow the formatting requirements. Please note that DocRefIDs must not include any non-alphanumeric characters, excluding periods and dashes. Prohibited non-alphanumeric characters include but are not limited to_, @, +, &, ! and *.

Updated: 04-18-18

Q10. Do I need to correct data submitted in my FATCA Record file?

The record-level error codes 8001 (Pooled Report Error), and 8007 (Account Report Error), and 8013 (Nil Report Error) indicate errors found with specific data elements in the record that must be corrected through a resubmission. In these cases the notifications will contain a “FieldErrorGrp” for each field-level error, with a description of the error (“FieldErrorTxt”) and the XML path for the data element (“FieldNm”) in error. Field-level errors are provided alphabetically by descriptionin the order in which they appear in the FATCA Schema in Figure 4-2 ICMM Field-level Errors for Electronic FATCA XML Reports PDF(pdf 147KB). Each field-level error must be corrected to resolve the record-level error.

Updated: 03-24-18

Q11. How do I submit my corrected, amended, or void data?

The procedures to correct, amend, or void specific records are below:
When a filer resubmits corrected record data in response to a “valid file with errors” notification from the IRS for an electronically submitted file, the following changes must be made within the “DocSpec” element for the corrected record:

  • The “DocTypeIndic” element must be “FATCA2” to denote a corrected record
  • The “CorrMessageRefId” element must be set equal to the “MessageRefId” for the original file in which the record being corrected was contained
  • The “CorrDocRefId” element must be set equal to the “DocRefId” for the original record being corrected
  • All fields identified in the error listing for the record in the notification must be corrected.
    In addition, all other record elements from the original record submission must be included, and the resubmitted file with the corrected record data must represent a valid FATCA XML file.

Amended records in which a filer chooses to amend (change or edit) previously submitted records are prepared similarly to corrected records. To submit an amended record, the filer must make the following changes within the resubmitted record:

  • The “DocTypeIndic” element must be “FATCA4” to denote an amended record
  • The “CorrMessageRefId” element must be set equal to the “MessageRefId” for the original file in which the record being amended was contained
  • The “CorrDocRefId” element must be set equal to the “DocRefId” for the original record being amended
  • All fields in the amended record must have values that the filer wishes to report to the IRS for the relevant account or pooled report.

Voided records in which a filer wishes to delete a previously submitted record are submitted in the following manner:

  • The “DocTypeIndic” element must be “FATCA3” to denote a voided record
  • The “CorrMessageRefId” element must be set equal to the “MessageRefId” for the original file in which the record being voided was contained
  • The “CorrDocRefId” element must be set equal to the “DocRefId” for the original record being voided
  • All fields in the voided record must have the same values as the original record being voided (deleted).

Updated: 03-03-16

Q12. We received an error message regarding the amount shown in the payments field in Schema version 2.0. We reviewed the file but were unable to determine why a record-level error was returned. The IRS replied that the error was issued because the file included more than two zeroes to the right of the decimal place in the field specified for payment amounts. The additional zeroes were routinely added by our back-end system and are not significant. Why this was considered an error?

The IRS agrees that this scenario is not an error by the filer. The ICMM system will misinterpret a MonAmnt_Type element with additional trailing zeroes after the second position to the right of the decimal point in the element; as a result the filer will receive a Valid File Notification (with Record-Level Errors) or NVF Notification because of the additional trailing zeroes. The MonAmnt_Type data with additional trailing zeroes are valid according to the FATCA XML Schema v2.0.

As of March, 24, 2018 this error condition is no longer being reported in NVF Notifications. For notifications received prior to that date, filers that receive an error for that reason (schema-valid MonAmnt_Type value with additional trailing zeroes) may ignore that error in the NVF Notification; those conditions do not require correction. However, please correct all other documented field-level errors on any other elements in the NVF notification.

Updated: 03-24-18

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1.4 ICMM Record-level Error Notifications for Paper Forms 8966

Q13. What does this notification mean?

The IRS has received your Form 8966 and has identified errors in your document that require correction. You will need to correct all identified record-level errors and resubmit the Form. Please mark the new form as “Corrected” by checking the box at the top of the first page, and send to the address indicated in the instructions.

Updated: 03-24-18

Q14. What does the record-level error code in the notification mean?

The record error code on the paper notification is one of 4 record-level error codes provided in Table 4-3 which also contains descriptions and remedial actions for each error type.

Added: 09-14-15

Q15. What do “Field ID” and “Field Error Description” in the notification pertain to?

These values provide the Part and Line reference, and standard description for each error found on your submitted Form 8966. Field-level errors are provided alphabetically by description in Figure 4-4 ICMM Field-level Errors for Paper ReportsPDF (pdf 101KB). Each field-level error must be corrected to resolve the overall record-level error.

Added: 09-14-15

Q16. Do I need to resubmit the complete form or just corrections to the errors?

Corrected Forms 8966 must have complete entries for all required fields. Please resubmit all data, including corrected data, from your original Form 8966 on your corrected form.

Added: 01-17-17

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1.5 ICMM Paper Pooled Report Error Notification for Paper Forms 8966

Q17. How do I resubmit my paper Form 8966?

The IRS has received your Form 8966 submitted as a pool report and we have identified errors and inconsistencies in your document that require correction. You will need to correct all identified record level errors and resubmit the Form. Please mark the new form as “Corrected” by checking the box at the top of the first page, and send to the address indicated in the instructions

Added: 01-17-17

Q18. Do I need to resubmit the complete form or just corrections to the errors?

Corrected Forms 8966 for pool reporting must have complete entries for all required fields. Please resubmit all data, including corrected data, from your original Form 8966 on your corrected form.

Added: 01-17-17

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1.6 ICMM Paper Pooled Error Notification for Paper Forms 8966

Q19. What does this notification mean?

The IRS has received your Form 8966 and has identified errors in your document that require correction. You will need to correct all identified record-level errors and resubmit the Form. Please mark the new form as “Corrected” by checking the box at the top of the first page, and send to the address indicated in the instructions.

Added: 01-17-17

Q20. Do I need to resubmit the complete form or just corrections to the errors?

All submitted Forms 8966, whether original, corrected, amended, or void forms, must have complete entries for all required fields. All appropriate fields should be populated with either data from the originally filed form or changes to reflect the corrections to the errors or amendments.

Added: 01-17-17

Q21. How do I resubmit my paper Form 8966?

To resubmit a Form 8966, paper filers should submit a new Form 8966 with all appropriate fields populated with either data from the originally filed form or changes to reflect corrections or amendments:

  • To correct an account or pooled report, in response to error notifications received from the IRS, make corrections to the fields in the part and line numbers, specified in the error notification, and check the “Corrected Form” box
  • To amend or change an account or pooled report, submitted on a previously filed Form 8966, change the fields that need edits and check the “Amended Form” box
  • To void or delete a previously filed Form 8966, check the “Voided form” box.

In all cases, fields from the original submission, that are not being corrected or edited, must be populated with the same data as the original filing (note: voided forms must include the same data as the original form being voided).

The table in, Figure 4 3 ICMM Record-level Processing Error Codes (paper filing)PDF (pdf 10KB), provides the codes, descriptions, and remedial actions needed for record — level errors ICMM will detect in records on paper Forms 8966. Four digit record-level error codes are always provided when record-level errors are present. Unlike the electronic case, in which a single file can contain multiple account reports and pooled reports as records, a single Form 8966 is considered to be a single, standalone record. A filer can only document a single account or pooled report on each paper Form 8966, and cannot file both types of reports on a single form. Also, unlike the electronic case, there is no way to identify a specific Form 8966 submitted by a filer; that is, there is no analog on the paper filing side to the MessageRefId and DocRefId data elements in the FATCA XML schema which can be used to exactly identify prior paper records. The IRS will need to analyze the filing history from a given filer to determine if corrections to errors on specific paper account and pooled reports have been provided. Because there is no way to directly correlate corrections to original submissions with errors, the record-level errors in electronic filing centered on corrected or amended reports with no matching originals have no paper counterparts, so the range of paper record-level errors is smaller.

Updated: 03-03-16

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ICMM TIN

Q1. What triggers a “TIN not in IRS specified format” error message?

The “TIN not in IRS specified format” error is generated when a non-GIIN value for a TIN data element is not in a valid format for a U.S. TIN. A value for a TIN data element must be either in a GIIN format or in one of the following formats for a U.S. TIN to be considered valid when filed:

  • Nine consecutive numerical digits without hyphens or other separators (e.g., “123456789”)
  • Nine numerical digits with two hyphens, one hyphen entered after the third numeric digit and a second hyphen entered after the fifth numeric digit (e.g., “123-45-6789”)
  • Nine numerical digits with a hyphen entered after the second digit (e.g., “12-3456789”)

If a filer has confirmed that the Account Holder is not required to have a US TIN in the agreed upon format then the filer does not need to re-file to correct this specific error. Any other errors included in the notification must be corrected and the filer should re-submit a corrected file for those errors only. The Account Holder TIN must be provided and cannot be blank characters in the TIN data sub-element.

Updated: 03-24-18

Q1a. What triggers a “TIN not in IRS specified format, contains only one character repeated,” error message?

The “TIN not in IRS specified format, contains only one character repeated» error is generated when a US TIN is in one of the valid formats specified in Q7 above, but consists of nine digits that are all the same (ex. 555555555, 111-11-1111, 33-333333) or when a non-US TIN, which does not have to conform to the formats specified in Q7, consists of digits or characters that are all the same (ex. 9999999, XXXXXXX). A valid TIN will not consist only of one repeated character, regardless of country of origin.

If a filer has confirmed that the Account Holder is not required to have a US TIN in the agreed upon format then the filer does not need to re-file to correct this specific error. Any other errors included in the notification must be corrected and the filer should re-submit a corrected file for those errors only. The Account Holder TIN must be provided and cannot be blank characters in the TIN data sub-element.

Updated: 03-24-18

Q1b. What triggers a “TIN not in IRS specified format, contains non-numeric characters,” error message?

The “TIN not in IRS specified format, contains non-numeric characters» error is generated when a US TIN is in one of the valid formats specified in Q1 above, but includes any characters other than numeric digits (1-9) or «-» in the positions specified in Q1. A valid US TIN will not include any non-numeric characters.

If a filer has confirmed that the Account Holder is not required to have a US TIN in the agreed upon format then the filer does not need to re-file to correct this specific error. Any other errors included in the notification must be corrected and the filer should re-submit a corrected file for those errors only. The Account Holder TIN must be provided and cannot be blank characters in the TIN data sub-element.

Updated: 03-24-18

Q2. I have verified that the US TIN (in SSN or EIN form) for my reporting FI, intermediary, account holder, or substantial owner is correct; why am I getting the “TIN not in IRS specified format” error?

Though the nine digits in the US TIN you have provided are the correct TIN for the person or entity being documented, you may have used an incorrect format for the TIN. Please see Question 1 above for the correct formats to be used for US TINs in FATCA reporting.

Updated: 03-24-18

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Additional Resources and Support

FATCA ICMM File Notification Support

If you need additional assistance with your FATCA file notifications please submit your question to ICMM Customer Support. Please include in your email the notification code and the notification RefId from your notification with a description of your problem or question.

Telephone support for FATCA file notifications is available from 8:00 a.m. to 5:00 p.m. (U.S. Central Time), Monday through Friday. From the United States of America, call toll free at 1-866-937-4130. Support is in English only.

Please note: The above email box and phone support are only for answering questions about notifications sent from the IRS ICMM system.

The ICMM support team cannot respond to tax law questions regarding the FATCA regulations.

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Pre and Post Transmission Related Questions

If you have additional questions about the International Compliance Management Model, please submit your question.

The ICMM Webpage and ICMM FAQs are updated on a regular basis with information related to ICMM and with answers to ICMM questions. However, you may submit a question here if you do not find the information you need elsewhere. Due to the volume of questions received, the IRS is unable to provide personalized responses, but answers to the most frequently asked questions will be posted periodically.

NOTE: Do not provide any personal identification information such as your name, taxpayer identification number, social security number, address, or telephone number.

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Additional Support

FATCA Help:

Additional FAQs and information is available for the FATCA Registration System, FATCA – FAQs General, FATCA FFI List, FATCA – Form 8938 FAQs, IDES Website, and FATCA IDES Technical FAQs

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