Updated guidance reflects extension of temporary relief for foreign financial institutions regarding reporting of U.S.TINs
The tax authority of Liechtenstein on February 27, 2025, updated its FATCA reporting technical guidance, reflecting the extension of temporary relief for foreign financial institutions regarding the reporting of U.S. taxpayer identification numbers (TINs).
The updated guidance aligns with , which extends the relief initially granted by . Under this relief, foreign financial institutions reporting for calendar years 2022 to 2027 will not be deemed significantly non-compliant when using U.S. dummy TIN codes for missing U.S. TINs for pre-existing U.S. accounts, provided they meet the requirements outlined in the notices.
Notice 2024-78 specifies additional requirements for relief starting with the 2025 reporting period. Foreign financial institutions must report the foreign taxpayer identification number (FTIN) of the U.S. account holder or controlling person, if available, and the city and country of residence in the "AddressFix" reporting element.
Foreign financial institutions are required to retain records of compliance policies and procedures until the end of 2031. Moreover, Section 4.1 of the guidance has been revised to mandate that when using a U.S. TIN or dummy TIN code for a U.S. substantial owner of a non-U.S. entity, the "TIN issued by" field must be completed with the country code "U.S."
Read a March 2025 report prepared by the 乐鱼（Leyu）体育官网 member firm in Liechtenstein