Bahamas update Economic Substance Reporting Overview

On 18 December 2019, the Bahamas Ministry of Finance issued an updated Reporting Overview with regard to Economic Substance Reporting (Link).

An updated schedule to the Bahamas CRS legislation will be published in the next weeks.

All portal queries should be directed to:

For queries related to the site and/or information on the reporting obligations, please submit emails to

Italy clarifies US TIN reporting

On 10 December, Italy issued a clarification on the reporting requirements for Financial Institutions (“FIs”) under the Foreign Account Tax Compliance Act (“FATCA”). Italy states that FIs that failed to obtain Tax Information Numbers (“TIN”) for pre-existing customer accounts will not violate FATCA if the institutions follow the instructions in the U.S. Internal Revenue Service (“IRS”) Frequently Asked Questions (“FAQs”) (Link).

IRS updates FAQ on FATCA

On 18 December 2019, U.S. Internal Revenue Service (“IRS”) updated its Frequently Asked Questions (“FAQs”) – General on the Foreign Account Tax Compliance Act (“FATCA”) (Link).

Question 16 in the section “FATCA Certifications” has been updated to support users in understanding the respective requirements:

Question 16: I terminated my FFI agreement (Rev. Proc. 2017-16, 2017-3 I.R.B. 201) by canceling my account in the FATCA registration system and no longer have a GIIN. How do I submit a certification?

Ireland releases eBrief on Guidance Notes on the Implementation of FATCA

On 9 December 2019, Irish Tax and Customs released updated Guidance Notes on the Implementation of the Foreign Account Tax Compliance Act (“FATCA”) (Link). The eBrief No.206/19 contains an update to Tax and Duty Manual Part 38-03-22 at paragraph 4.3. A summary of a new FAQ the IRS has issued regarding the non-reporting of TINs by Financial Intuitions from the year 2020 onwards has been added.

While every effort by Irish Tax and Customs is made to ensure that the information given in these guidelines is accurate, it is not a legal document. Responsibility cannot be accepted for any liability incurred or loss suffered as a result of reliance on any matter published.

Ukraine – U.S. FATCA IGA enters into force

On 9 December 2019, the U.S. Internal Revenue Service (“IRS”) announced that the Intergovernmental Agreement (“IGA”) to facilitate reporting under the Foreign Account Tax Compliance Act (“FATCA”), signed 7 February 2017 with the Ukraine, entered into force with effect from 18 November 2019 (Link).

The IGA was ratified on 29 October 2019 (Link-Blog).

Please see PwC Ukraine’s Flash Report for more information (Link).

Liechtenstein expands List of Participating Jurisdictions

On 9 December 2019, the Liechtenstein Tax Authority issued Gazette No.332, 333 and 334 expanding the list of partner jurisdictions under the Multilateral Competent Authority Agreement (“MCAA”) on the implementation of automatic exchange of financial account information under the Common Reporting Standard (“CRS”). The following countries have been added to the list:

The first exchange with the three jurisdictions is planned to take place in 2021.

European Union letter to U.S. Secretary of the Treasury

On 3 December 2019, the Presidency of the Council of the European Union sent a letter to the U.S. Treasury Secretary, Steven Mnuchin, highlighting the risk that European banks might close the accounts of Accidental Americans, who are also EU citizens, on 1 January 2020 (Link).

With regard to the issue of a missing U.S. tax identification number (“TIN”) for those Accidental Americans, the European Union is pleased to see the recent changes on Question 3 in the Frequently Asked Questions (“FAQs”) – General on the Foreign Account Tax Compliance Act (“FATCA”) (Link-Blog).

Further, the European Union urges to expand the FATCA FAQs by adding technical exchanges between the U.S. Internal Revenue Service (“IRS”) and the European Union.

IRS releases New Terms of Agreement and Resubmission Requirements

On 9 December 2019, the U.S. Internal Revenue Service (“IRS”) issued an update to the Quick Alert issued 21 August 2019, which stated that all individuals listed as a Principal or Responsible Official will be required to sign a new Terms of Agreement when adding individual(s) and/or Provider Option(s) to an e-file application.

The application status will change to “Resubmission Required” and must be submitted to complete the application process. The EFIN will remain active during this process (Link).

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