Frequently Asked Questions (FAQs)
In addition to the FATCA FAQs currently available on the International Tax Information Exchange website, here are some Frequently Asked Questions about accessing and using the Tax Information Exchange Portal.
Tax Information Exchange Portal FAQs
Q) What are the new updates for Tax Year 2016 Reporting?
A) The Competent Authority has enacted the following changes to match the changes made to the 5124 schema – Version 2.
- Filer Category has been added to the TIE Portal Registration Field.
- Updates to the File Creation Instructions:
- AccClosedInd and IndvidualInd fields have been added to the reporting fields
- SponsedEIN has been renamed to SponsedGIIN
- New validations have been to the schema for the AcctResCountryCode, AcctountHolderType, and SponsedResCountryCode fields.
Q) My Financial Institution has multiple GIINs. Do I need usernames for each GIIN or can I process all under one user ID?
A) Reportable Accounts or Nil Reports must be processed individually for each GIIN and you will need to have Usernames for each GIIN. Submit separate New User Registration requests for each GIIN. File processing is validated by each GIIN and if reportable accounts are uploaded for a different GIIN in the file than the one the user is logged into the portal as, the records will error out.
Q) My Financial Institution is sponsoring multiple FI’s. Do I need usernames for each GIIN or can I process all under one user ID?
A) Reportable Accounts or Nil Reports must be processed individually for each sponsored GIIN and you will need to have Usernames for each sponsored FI. Submit separate New User Registration requests for each sponsored FI. File processing is validated by each GIIN and if reportable accounts are uploaded for a different GIIN in the file than the one the user is logged into the portal as, the records will error out.
As a reminder, Sponsored Investment Entities domiciled in The Bahamas that fall under Article IV(B)(3)(c) of Annex II of the Model 1 IGA 1 between The Bahamas and the United States are classified as Deemed-Compliant FFIs. A nil report is therefore not necessary for such FFIs, however, if a Sponsoring Entity of a Sponsored Investment Entity or Sponsored Controlled Foreign Corporation identifies any U.S. reportable accounts, the sponsoring entity must register the sponsored entity with the IRS on or before the later of December 31, 2016 and the date that is 90 days after such account is first identified.
The IRS Registration Portal has been enhanced to allow the addition of sponsored entity information and users are able to submit a file containing individual or multiple records.
Sponsored Closely-Held Investment Vehicles, found in Article IV(c), will not need to register for usernames or GIINs. Pursuant to the terms of the IGA, those FIs may rely on their Sponsored Entities to perform their reporting obligations.
It should be noted that while Deemed-Compliant FFIs may not have to obtain a GIIN for local FATCA reporting purposes, they may still be required to obtain one for withholding purposes. It is the responsibility of FIs to obtain appropriate legal and tax advice regarding their responsibility.
Q) I have my log in information from last year, but it is not working. What should I do?
A) Registered Users from previous tax years will not be able to reuse their registration from a previous year. Please follow the registration process as if you were a new user. Accordingly, all registration details, from last year’s reporting period, have been purged in the portal to ensure security. Therefore, all GIIN’s will require registration on the TIE portal prior to reporting. This requirement was established in consultation with the FATCA Working Group which included representative organizations of the Financial Services Industry and Financial Services Regulators. The purpose of the requirement is to support data security and confidentiality.
Q) I am registering as a new user. What are the differences between the two options (“I am reporting for my own organization” or “I am reporting on behalf of another organization (i.e. Third Party reporting)”)?
A) The option to select “I am reporting for my organization” should be used if you are employed by the organization or subsidiary the GIIN is registered to. The option to select “I am reporting on behalf of another organization” should only be used by third party service providers fulfilling reporting obligations on behalf of a Bahamas Financial Institution.
Q) I am trying to register as a new user, but I receive an error message “Sorry, we do not recognize your financial institution and GIIN combination. Please try again.” What should I do?
A) The Portal registration process requires that your FI information matches the information from the IRS. Refer to https://apps.irs.gov/app/fatcaFfiList/flu.jsf to ensure your information matches the information from the IRS. Please note: FI Branches will need to replace the hyphen in the official name with a space (i.e. EXAMPLE BANK – BRANCH should be entered as EXAMPLE BANK BRANCH).
Q) I submitted a New User Registration but I haven’t heard anything yet. What should I do?
A) All registration confirmations will provide the email address for the Financial Institution’s Key Officer/Responsible Officer responsible for responding to New User Registration request. If you haven’t received an approval or denial of your registration request you can follow-up directly with the email address provided. Registration requests are valid for 7 days and you may need to submit your registration request again if it is not responded to in that time frame.
Q) I received a New User Registration request. What do I need to do?
A) Registration requests must be responded to within 7 days. To respond to the request, go to the Tax Information Exchange Portal and after clicking the Enter Code button, enter the registration code and approve or deny the new user registration request. Click these links for documentation including screenshots or a video of the process.
Q) Please explain what Key Officer/Responsible Officer are as it relates to the Tax Information Exchange Portal.
A) The terms “Key Officer”, “Responsible Officer” and “Reporting Officer” all refer to the individual within an organization who has been designated as having the responsibility for FATCA reporting and/or GIIN Registration. This individual must review and respond to all new user portal registrations before users can gain access to the portal to process files or Nil Reports.
Q) Our Key Officer/Responsible Officer is out of the office (or no longer with the organization) and not able to respond to registration requests. What are our options?
A) If the Key Officer/Responsible Officer will be out longer than 7 days (amount of time the registration code is active), the organization can submit a request to have the Key Officer/Responsible Officer updated in the system. Once it is updated and confirmed by the Competent Authority, users will need to submit a new registration request so the request is sent to the new Key Officer/Responsible Officer. Requests must be sent on company letterhead from the most senior officer in the organization. If the person listed as the new Key Officer/Responsible Officer is the most senior officer, then the letter must be sent from the next most senior officer of the organization. The request must include the GIIN, name of the current Key Officer/Responsible Officer, full name of new Key Officer/Responsible Officer, their email address, their phone number, requestor’s name, title, email and contact phone number. Requests can be scanned and emailed to firstname.lastname@example.org. If the individual is no longer with the organization, the IRS FATCA Registration should also be updated (FATCA Registration System Frequently Asked Questions).
Q) We want two users to access the portal, is this possible?
A) Yes, you can have more than one user in the Portal as long as their registration request is approved by the Financial Institution’s Key Officer/Responsible Officer. User actions (file upload, submission, etc.) are tracked by each user ID and portal email notifications are sent to all approved registered users for each GIIN..
Q) How is portal access removed for someone who no longer needs access?
A) The Key Officer/Responsible Officer or other senior official with the organization must submit a request to disable a TIE Portal user’s access in writing on company letterhead. The request must include the GIIN, full name of the user and their portal username, requestor’s name, title, email and contact phone number. Requests can be scanned and emailed to email@example.com.
Q) I tried to log in but had issues with my password and it states I am temporarily locked out and try again later. How long must I wait?
A) In this situation, you must wait 30 minutes from your last log in attempt. You cannot submit a password request during this time as you must also wait the 30 minutes.
Q) I tried to reset my password online but I could not do so or I cannot remember my Security Question answers. What can I do?
A) You will need to submit a request on company letterhead to the Competent Authority. You can send your scanned letter to firstname.lastname@example.org with the following details: Your name, User ID, GIIN, Phone Number, Nature of your request (Password reset). The Competent Authority will review all requests confirming user access and authorization prior to resetting user passwords. Passwords cannot be emailed and you will be contacted by phone with your reset password.
Q) Does the system have a timeout feature?
A) Yes, users logged into the system will be logged out from portal processing after 30 minutes of inactivity. Users can still access Portal Help and About FATCA links but cannot do any file processing when logged out.
Q) What steps can I do to prevent errors in my file?
A) Review the File Creation Instructions for details on file creation guidelines, notes and details on the system validation your file will go through during processing. If using an Excel file, Make sure your file has no special formatting (i.e. filters, outlines, hidden columns, etc.) and all data is formatted as “text”. Required fields are listed in the Field Schema starting on page 3 where Validation column lists “Not Null”. These validations follow the IRS Requirements for FATCA data submission.
Q) In order to upload my file do I need to enter a Business License ID? What if I do not have one?
A) If your organization has a Business License ID, enter it on the “Enter information for your financial institution screen.” If you do not have a Business License ID you do not need to enter anything in this field as it is not required.
Q) I uploaded my file, how long will it take to process it?
A) The system will process files in a first in first out order. Depending on the number of files uploaded, files should process within a short period of time (same day) however during high processing times (i.e. just prior to file submission deadline) files may take up to 24 hours to process.
Q) I uploaded a file but need to recall it. How do I do this in the portal?
A) Files cannot be recalled however, as long as you have not marked the file as Submitted, you can upload a replacement file using the “Upload a Replacement File” button. Prior uploaded data is replaced when a new file is uploaded.
Q) Can I add additional records after I have uploaded my file?
A) Additional records can be added to your original file data and uploaded using the “Upload a Replacement File” processing. The complete file of all reportable accounts must be uploaded (not just new records) as portal processing will remove any previously uploaded data before processing the new file.
Q) I uploaded my file but I have errors. What do I need to do?
A) To correct the errors, review the error listing to identify the rows of data in error and reason. Research the errors and update your file with corrected information. The complete file of all reportable accounts must be uploaded for processing again. Do not just correct the errors and upload those records – all file uploads must include all reportable accounts as each time a new file is uploaded, previously processed data is deleted from the system.
Q) Can I correct my errors in the portal?
A) No, Data cannot be viewed or edited within the portal. Data is uploaded from the portal but users cannot access their data in the portal. Only minimum information is provided about records in error status to help identify the records for correction in the original file. A complete file must be uploaded again once records in error are corrected.
Q) Can the Competent Authority correct my records in error?
A) No, the Competent Authority does not have the ability to edit, delete or add any records for Financial Institutions. The Financial Institutions are responsible for their data and must upload a file of their reportable accounts. If you have already uploaded a file, you can upload a new file using the “Upload a Replacement File” option in the portal. If you have already Submitted your file, you will need to request a Portal Override to upload a replacement file.
Q) I submitted my file / Submitted a Nil Report and now have more reportable accounts to include. How do I submit a Portal Override request?
A) To upload a new file after submitting a Nil Report or Submitting your file, you need to send an email to email@example.com to request a Portal Override to upload and submit a new file. You must include the following data: Your name, User ID, GIIN, Phone Number, Nature of your request (Portal Override due to…). Portal Overrides are subject to approval by the Competent Authority based on filing deadlines.
Q) How can I confirm the data uploaded to the Tax Information Exchange Portal?
A) The Account Management section of the Portal will list the file name and number of rows of data processed and number of rows in error. Once a file has been submitted, the confirmation email and onscreen message will list the file name and number of rows submitted. This can also be viewed in the Account Management section under Account History. It is recommended to retain the file and confirmation emails per your Financial Institution’s retention processes and auditor requirements.
Q) When Registering my Financial Institution on the TIE Portal, there is a required field for Industry, however I am not sure which category applies to me. Where can I find more information on which industry category my FI should select?
A) These categories are directly from the International Standard Industrial Classification of All Economic Activities (ISIC), Rev. 4 published by the United Nations Statistics Division. Please refer to the ISIC Rev 4’s webpage for details on different industry designations.
Q) What do the Confirmation emails tell us?
A) Each email sent during portal processing will include the GIIN and Legal Name for the Financial Institution in addition to the confirmation of the action taken. Email subject lines will include the email purpose and GIIN. Submission confirmations will also include the user name who completed the Submission.
Q) Does the Competent Authority review the data prior to providing it to the IRS?
A) It is the responsibility of each Financial Institution to confirm their data is complete and accurate prior to marking the data files as Submitted. The Competent Authority will create the IRS Transmittal File but not review the uploaded data for accuracy. You may be contacted in the event the IRS rejects the Transmittal File due to issues with your reportable accounts.