Tax Identification Number (TIN) Update

The International Tax Authority (ITA) wishes to remind all Financial Institutions (FI’s) that mandatory TIN information in filings was implemented for 2020 reporting year and onwards.  If a FI made a filing without a TIN, but rather, inserted any one of the IRS acceptable sequential codes such as 222222222, a record-level error notification would have been generated, however; the filing would be accepted by the IRS.

These codes give an indication to the IRS as to why a TIN was not reported in the filing.  Where an error has been received by a FI, please note, corrections must be made within 120 days.  Where an error was not corrected within 120 days, the IRS will not automatically find significant non-compliance, but rather, if the IRS makes contact with a FI, a FI should have in its possession documented attempts made to obtain any missing TIN from its filing(s).


The ITA also wishes to inform FI’s that the BVIFARs portal has been updated to allow for

an “ISSUED BY” option, where the account holder that is not assigned a TIN or is not a holder of a TIN, but the account has a substantial US owner.  This update addresses Q3 of the IRS FAQ.

For completing filings in this circumstance, please see the following steps and details below.

  • The FI must include the TIN element for both Account Holder and Substantial Owner.  If both are US individuals/entities, the FI should include the US TIN for both.  If only one is a US individual/entity, then the FI will not receive an error message as long as the FI include a validly formatted US TIN in the TIN element for the US individual/entity and the foreign TIN (with the “TIN Issued by” element populated with the issuing country code) for the foreign individual/entity.   If there is no foreign TIN available for the foreign individual/entity, the FI may include its country code in the “TIN Issued by” element and the characters “NA” (to indicate “Not Available”) in the TIN element. (See Example below)
  •  <ftc:AccountHolder>
    <sfa:TIN   issuedBy=”LI”>NA</sfa:TIN>

    <sfa:TIN  issuedBy=”US>123456789</sfa:TIN>

  • If the FI omit the TIN element entirely for either the Account Holder or Substantial Owner, or insert blank spaces in the TIN element, the FI will receive a “TIN Not Populated” error, regardless of whether the other TIN field is populated with a US TIN.


Kindly note that the Portal will be offline commencing Monday 21 February, 2022. Please note that the ITA will provide an update during the course of the week of 21 February, 2022 indicating when FI’s can proceed to access the portal and make filings under the update feature.

For more information on the filing format please see below which could be found on the IRS website at:

For further information, questions or concerns please feel free to contact us via the following means:  telephone number:  1 284 343 4415, email address: