On December 30, the Internal Revenue Service (IRS) released Notice 2023-11, Foreign Financial Institution Temporary U.S. Taxpayer Identification Number Relief:
As an overview, this notice is a refined and continued extension of temporary relief for Foreign Financial Institutions (“FFI”) in a Model 1 Intergovernmental agreement (“IGA”) jurisdiction who are missing US TINs. If US TINs are not collected/provided, then the FFI will be considered non-compliant and subject to withholding.
It is important to note that this temporary relief will apply to tax years 2022, 2023 and 2024, and only applies to preexisting accounts. FFIs with new account holders will not be provided with relief under this notice, so they should be collecting US TINs for new account holders.