SECTION 3. EXTENSION OF

TEMPORARY U.S. TIN RELIEF

.01 Extension of relief for reporting on certain preexisting accounts that are U.S. reportable accounts

This notice extends, for calendar years 2025, 2026, and 2027, the temporary relief provided in Notice 2023-11 for reporting Model 1 FFIs required to report U.S. TINs for certain preexisting accounts, subject to the conditions set forth in this notice. Reporting Model 1 FFIs that comply with sections 3.02 and 3.03 of this notice will not be treated as in significant non-compliance with their obligations under an applicable Model 1 IGA solely because of the failure to report a required U.S. TIN with respect to a preexisting account. Section 3.04 of this notice limits this relief to reporting Model 1 FFIs that are in an eligible jurisdiction that makes good faith efforts to increase the likelihood that U.S. citizens residing in that jurisdiction will report their U.S. TINs to the FFIs and that takes other steps specified in section 3.04.

This relief is limited to reporting on preexisting accounts. It does not apply to U.S. reportable accounts opened after the determination date specified in the applicable Model 1 IGA, including new accounts held by account holders of preexisting accounts.

Nothing in this notice prevents the U.S. Competent Authority from finding significant non-compliance by reporting Model 1 FFIs that do not report required U.S. TINs for preexisting accounts and

that do not comply with the relief requirements of this notice or Notice 2023-11, as applicable. Further, nothing in this notice or Notice 2023-11 prevents the U.S. Competent Authority from finding significant non-compliance due to a failure to satisfy an obligation under the applicable Model 1 IGA other than a failure to obtain and report each required U.S. TIN for preexisting accounts.

.02 Requirements for reporting Model 1 FFIs To obtain the relief for preexisting accounts described in section 3.01 of this notice for the 2025, 2026, and 2027 calendar years, for each U.S. reportable account (including new accounts) with a missing required U.S. TIN, the reporting Model 1 FFI must do the following:

(1) obtain and report the date of birth of each account holder that is an individual and controlling person whose U.S. TIN is not reported;

(2) annually request from each account holder any missing required U.S. TIN, as described in further detail in section 3.03 below;

(3) annually search electronically searchable data maintained by the reporting Model 1 FFI for any missing required U.S. TINs;

(4) report an accurate TIN Code for each account that is missing a required U.S. TIN;

(5) if the FFI’s electronically searchable account information contains a foreign taxpayer identification number (or functional equivalent) assigned to a taxpayer by its country of residence (FTIN), report an FTIN for each specified U.S. person that is missing a required U.S. TIN; and

(6) using the AddressFix element, as described further below, report the city and country of residence for each specified U.S. person with a missing required U.S. TIN.

The AddressFix element is intended to be used generally for all address reporting. To ensure conformity of data reporting and the IRS’s ability to process reported data, reporting Model 1 FFIs should use AddressFix for all address information to the extent possible and may use Address

Free as a supplemental element. However, to comply with requirement (6) of this section, the only requirement is that the city and country of residence of the specified U.S. person must be included in AddressFix.

.03 Annual request for missing required U.S. TINs

Reporting Model 1 FFIs must also make annual requests for missing required U.S. TIN information. To satisfy the requirement to make an annual request from each account holder for missing required U.S. TINs, reporting Model 1 FFIs must use the method of communication that is, in the FFI’s reasonable judgment, most likely to reach the account holder. In addition, the communication must include either of the following:

• the web address of the State Department’s Joint FATCA FAQs (as of the publication date of this notice, https:// travel.state.gov/content/travel/en/international-travel/while-abroad/JointForeign-Account-Tax-ComplianceFATCA-FAQ.html), ² or

• (i) a copy of the FAQs described in the preceding bullet and (ii) either

  • a copy of the relief procedures provided by the IRS for certain former citizens, or

  • the web address for such procedures (as of the publication date of this notice, https://www.irs. gov/individuals/internationaltaxpayers/relief-procedures-forcertain-former-citizens). FFIs seeking to obtain relief under this notice for the 2025, 2026, and 2027 calendar years must retain records of the policies and procedures adopted to satisfy this requirement and documentation that those policies and procedures were followed to establish its compliance with the requirements of this section until the end of calendar year 2031. To obtain the relief described in this notice, the FFI must also retain until 2031 any records or documentation adopted in previous years for the purpose of obtaining relief under Notice 2023-11 to the extent applicable. .04 Eligible Model 1 IGA jurisdictions For a reporting Model 1 FFI to be eligible for the relief described in this section

2 The Joint FATCA FAQs provide information on how to obtain an SSN, how to renounce U.S. citizenship, and relevant U.S. tax consequences (including a link to the IRS’s relief procedures for certain former U.S. citizens). Additionally, FFIs may wish to include a direct link for U.S. citizens and residents seeking to obtain a U.S. TIN (as of the publication date of this notice, https://www.ssa.gov/foreign/foreign.htm).

November 12, 2024 1112 Bulletin No. 2024–46

with respect to reporting for a particular calendar year or other appropriate reporting period, the applicable Model 1 IGA jurisdiction must make good faith efforts, by the date that is nine months after the end of the calendar year to which the information relates, to do the following:

(1) Encourage U.S. citizens resident in the jurisdiction to provide U.S. TINs to FFIs when requested;

(2) Take measures to enforce compliance by reporting Model 1 FFIs identified by the U.S. Competent Authority to the Model 1 IGA jurisdiction as potentially non-compliant;

(3) Encourage FFIs located in a Model 1 IGA jurisdiction to not discriminate against U.S. citizens that do provide a U.S. TIN; and

(4) If notified by the U.S. Competent Authority, take steps to conclude Competent Authority Arrangements with the U.S. Competent Authority, to implement an IGA, amend an Annex II to an IGA, or exchange country-by-country information.