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Issue 41566

TINs and GIINs

Issue Statement: Nearly half of FFI 8966s do not contain valid TIN/SSNs. This makes matching filers’ returns with 8966s very difficult. IRS believes that if filers reported the GIINs on their 8938s in their individual returns (now optional) this would facilitate matching. IRS would like this to be mandatory but Treasury mgt. is concerned by compliance issues. To assist filers, IRS has developed an online “FFI download tool”. TIGTA has endorsed this. But the tool works badly (I’ll explain if asked) and must remain optional. There is a simple solution. FFIs should include their GIINs on their monthly statements, much as most now include BICs and IBANs. The cost for FFIs is trivial and filers will have the necessary information right at hand.

Goal Statement: To determine how to make it possible for taxpayers to supply their foreign financial institution’s Global Intermediary Identification Number (GIIN) on Form 8938.

TAP RECOMMENDATION

Issue 41566 The IRS should determine if one or both of the following proposals can be implemented:

1) Improve the “FATCA Foreign Financial Institution (FFI) List Search and Download Tool” (found at this link: https://apps.irs.gov/app/fatcaFfiList/flu.jsf) by doing the following:

a) By making it more clear to taxpayers using the tool how to identify the GIIN that applies to each foreign account the taxpayer holds,
b) By enabling the tool to be searched using both accents in Latin script as well as scripts other than Latin scripts, such as Cyrillic, Aramaic, Hebrew, Japanese, etc., and
c) By making the tool’s interface available in a larger variety of languages,
and/or,

2) Require the relevant foreign financial intuitions to include the applicable GIIN on their clients’ monthly bank statements

IRS Action:Not adopted

Issue 41566

There is always room for improvement, however, the FATCA budget was slashed to the bare minimum and this is not considered a priority. It should be noted that if an individual cannot find its exact FI (e.g., Xbank of the world within different countries, the first five alphanumeric numbers are always going to be the same, what changes is the type of FI and their country code) they can still use the FATCA ID and put that on their 8938. This would then, at least, narrow it down for the IRS and would still be considered compliant. We have shared this option during external speaking events.
This would require a reg change and we previously lobbied for it when the regs were being drafted but were told that it would put too much of a burden on the FI. Also, we basically were never funded for FATCA implementation, so funding/resources are an issue. From our perspective, we would like to see additional reporting of the GIIN. But the only thing Treasury would agree to is optional reporting, as stated by the TAP.

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2019 TAP Annual Report

The 2019 TAP Annual Report highlights our key recommendations to improve IRS customer service and summarizes our key accomplishments and activities, including the 224 recommendations submitted to the IRS in 2019.

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