Extension of Temporary Relief for Foreign Financial Institutions to Report US Taxpayer Identification Numbers

This page explains the implications of the latest Notice issued by the U.S. Internal Revenue Service (IRS) for New Zealand Foreign Financial Institutions (FFIs) reporting for FATCA.

Notice 2024-78 provides an extension to the temporary relief for FFIs that have not been able to obtain U.S. TINs for their pre-existing FATCA reportable account holders and controlling persons.  It extends, and adds to, Notice 2023-11 (issued 30 December 2022) which outlines what FFIs must do to obtain relief from the U.S. determining they are significantly non-compliant with their FATCA obligations.

The key point to consider include:

• The relief extends for calendar years 2025, 2026, and 2027. This will not impact your 31 March 2025 (current year) FATCA reporting, due 30 June 2025. You should continue to follow the guidance under Notice 2023-11 for the current year in order to obtain the relief.
• It relates to pre-existing accounts only and does not apply to new accounts opened after the IGA came into force.
• FFIs must report a valid date of birth and use the prescribed TIN code where a U.S. TIN has not been obtained.
• The notice further sets out expectations for FFIs regarding their annual efforts to obtain U.S. TINs and documentation of such efforts. An FFI must retain records until 2031 of the policies and procedures it has adopted to meet these requirements and evidence that these actions have been undertaken.

FFIs are asked not to discriminate against U.S. citizens that are captured by FATCA reporting requirements.

IRS information