IRS Adds TIN Reporting Information to FATCA Systems FAQ

FATCA IDES Technical FAQs

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General Questions

A1. What is the International Data Exchange Services (IDES) system?

A2. What is the International Compliance Management Model (ICMM) system?

A3. What is the difference between an IDES Alert and an ICMM Notification?

A4. What is the frequency of IRS request for information on recalcitrant accounts?

A5. What is IRS expectation for HCTA response to request for information on recalcitrant accounts?

A6. What are IRS standards for HCTA data validation on recalcitrant accounts through the FATCA XML schema?

A7. How can HCTA and FFI obtain information as to system development progress and status?

A8. What types of technical support will be present during integration testing? How will the HCTAs, direct reporting NFFEs, and FFIs report issues with integration testing back to the IRS?

A9. What is the protocol for HCTAs to contact the IRS with technical issues or questions regarding IDES?

A10. What is the protocol for HCTAs to contact the IRS with issues or questions regarding reporting requirements?

A11. When can I enroll to use IDES?

A12. Does an HCTA need to get a GIIN?

A13. Will an API or standalone application be available to assist with data preparation?

A14. I am a Sponsoring Entity located in a Model 1 IGA jurisdiction. I am responsible for reporting on behalf of entities in Model 2 and non-IGA jurisdictions. When I attempt to enroll in IDES the system rejects my enrollment as coming from a Model 1 IGA jurisdiction. How can I use IDES as required to submit FATCA Reports?

A15. What are the differences between the FATCA XML Schema v1.0 and Form 8966 for “rounding off to the whole currency amount”?

A16. We have heard previous discussions that there would be an updated XML Schema for FATCA Reporting (Form 8966) for 2015. Could you advise when we will have the new version?

A17. I am a Direct Reporting Non-Financial Foreign Entity (NFFE) located in a Model 1 IGA jurisdiction. I am responsible for reporting to the IRS on substantial U.S. owners under the FATCA regulations. When I attempt to enroll in IDES, the system rejects my enrollment as coming from a Model 1 IGA jurisdiction. How can I use IDES as required to submit FATCA Reports?

A18. In the case of a Model 1 Option 2 (M1O2) arrangement, will a FATCA report filed by a Direct Reporting NFFE via IDES be routed directly to the US IRS or it requires HCTA’s approval before it gets onward forwarded to the US IRS?

System Availability and Design

B1. When will the IDES system be accessible for HCTA, direct reporting NFFE, and/or FFI use?

B2. What methods of file transfer are available for the IDES system?

B3. Is the IDES system IPv6 compatible?

B4. What information will be contained in the IDES Alerts?

B5. What information will be contained in the ICMM Notifications?

B6. How does an entity enroll for a testing window?

B7. When will the IDES system be accessible for testing purposes?

B8. I have not received an expected email about IDES enrollment. Are there any known issues related to this?

B9. How do I enroll for testing?

B10. What is the URL for accessing the test environment?

B11. During the Global IT Technical Forum call you indicated the IRS was preparing a maintenance release at the end of April that would address several reported defects. Could you inform us exactly what issues are being corrected?

B12. What is the procedure for reporting accounts with nil payments, such as a payment of zero or a negative balance? For example, a depository account may be held by a US Specified Person, have a positive account balance at 31 December, but have no payments of interest during the year.

Data Format and Structure

C1. What format should data be provided for the FATCA Report?

C2. Is there a naming convention for files pertaining to IRS request for information on recalcitrant accounts?

C3. When will sample XML files related to FATCA submissions be available?

C4. What is the format for sending metadata for file transfers to IDES (e.g., indicate a specific sender/receiver)?

C5. Is the XML data based on UTF-8 character encoding?

C6. Is there a &quotnot to exceed limit&quot on the size of the transmitted data file?

C7. Within the XML schema, is the SendingCompanyIN data element used to determine the origin of the file?

C8. How will the DocTypeIndics reserved for testing purposes will be used in production and test environments?

C9. How will the IRS handle updates to the XML schema? Will the system still be able to accept older versions of the schema or will prior years' files need to be updated to the current schema version?

C10. If an individual has only received certain payment types, should the other payment types be listed with a zero amount or should they be omitted from the report for that individual?

C11. What is the procedure for FFIs, direct reporting NFFEs, and HCTAs to verify test data prior to the launch of IDES?

C12. Can an HCTA create its own standard numbering format for the MessageRefID in the FATCA XML Schema for its financial institutions to use?

C13. What is the difference between corrected, amended and void files?

C14. When submitting a file with amended or corrected entries, what should be included in the MessageRefId field?

C15. How can HCTAs and filers ensure that the DocRefID they are using is unique across all reporting FIs?

C16. Are there any characters that are not allowed due to XML syntax rules and should be avoided in submitted XML documents?

C17. Are there any characters that pose a security threat and should be avoided in submitted XML documents?

C18. Can the restricted characters be included in escaped portions of the file (i.e. comments)?

C19. Which users are permitted to submit pooled reports? What is the procedure for submission of these reports?

C20. Which users are required to submit a Nil report? What is the procedure for submission of these reports?

C21. We're receiving a Notification that there are restricted characters in our file but when we check the FATCA XML Schema (Form 8966) we don't find any. What is wrong?

C22. How do I void a record reported in error using FATCA XML Schema?

C23. How do I amend a FATCA Report using FATCA XML Schema?

C24. The FATCA XML Schema v1.1 does not allow us to report a Substantial Owner as an organization. There is no place in the schema to populate a name. Should we place the organization name in the Last Name field?

C25. In 2016, I submitted a new Form 8966, FATCA Report, using the XML Schema v1.1. In 2017, I need to amend or correct a record on that report using XML Schema v2.0. What version of the schema do I need to use to amend or correct the record?

C26. I submitted a file through IDES containing corrected records for TY 2014. I received a Notification that the IRS could not match the CorrDocRefID element with any existing record. At a recent IT Technical Forum call the IRS indicated this was due to the presence of duplicate DocRefIDs in the system for that tax year. How can I submit a corrected, amended or voided record for TY 2014 if that situation exists?

C27. I am reporting under a Model 1 IGA and want to report a NPFFI, how do I report the account type and account balance?

C28. What is the FilerCategory element? When may the FilerCategory be used?

C29. When may the AccountClosed element be used?

C30. When may the AccountNumber element be used?

Data Transmission

D1. What are the procedures for sending files to IDES and/or ICMM systems?

D2. What are the procedures for sending metadata for files to IDES?

D3. Will requests from the IRS for information on nonconsenting U.S. accounts and nonconsenting nonparticipating FFIs be transmitted via email?

D4. Will IDES be used for transmitting the ICMM notifications?

D5. How will reciprocal data from the IRS be sent to an HCTA and in what format?

D6. How will the HCTA notify IDES of outages of their systems that will be receiving data?

D7. What is the procedure for sending corrected and/or amended data to receiving HCTA? Will the resubmission need to include only the corrected/amended entries or will the entire report need to be resubmitted?

D8. What required data validation should be done on the FATCA Report data prior to being submitted to IDES?

D9. I uploaded a FATCA Report to IDES 3 days ago. I received an Alert from IDES via e-mail that my file was successfully uploaded, but I have not received a Notification back from the IRS about the status of my FATCA Report. What could be wrong?

D10. What if I have mistakenly submitted my FATCA Report production files to the FATCA Report test environment?

D11. We're receiving an alert that there are too many files in package (RC026). What is wrong?

D12. Can we get individual confirmation that our files were received and approved by the IRS?

D14. I received an alert that the file I sent to the IRS via IDES was deleted after 7 days and not downloaded by the IRS. Please explain.

Data Encryption and Security

E1. What type of data encryption should be used prior to XML data transmission?

E2. What encryption standard will be implemented on the transmission path?

E3. How will passwords and public keys be controlled for data transmission to IRS?

E4. Who is responsible for data transmission security via encryption?

E5. What type of data encryption is used for reciprocal data sent to a HCTA?

E6. What are the requirements for digital certificates?

E7. Can the AES 256 key be re-used for subsequent data transmissions or does the key have to be different each time?

E8. Can the IRS provide additional detail regarding proper preparation of data for submission to IDES?

E9. Who needs to obtain a digital certificate?

E10. Can a digital certificate be shared by multiple organizations?

E11. If an FFI is submitting on behalf of other FFIs (i.e. a parent company submitting for its subsidiaries), does each entity need a certificate, or only the entity submitting the file?

E12. How does an organization obtain an SSL certificate if it does not have a Fully Qualified Domain Name (FQDN)?

E13. Is the use of ides-gateway.com or ides-support.com an acceptable FQDN for obtaining a digital certificate for IDES?

E14. If an entity has multiple domain names (e.g. different in each country, fund domain name vs. company domain name, etc.), is there any guidance on which domain name should be used for obtaining the certificate?

E16. Are there any recommended software packages that will be able to encrypt the.zip file containing the signed XML file, using AES 256 bit encryption with a randomly generated AES 256 bit key?

E17. During testing, we have experienced issues with decrypting the notification file. Are there any lessons learned or best practices that you can share?

E18. I received a CF acknowledgement message what should I do to identify and correct the error?

E19. We heard the IRS is changing the AES encryption cipher mode used during data packaging. What is this change?

E20. How do we create an Initialization Vector (IV)?

E21. As part of the CBC cipher mode, how do we exchange the Initialization Vector (IV)? Effective date: July 9, 2016.

E22. When updating the public key certificate in IDES, how will it affect files that were recently uploaded?

IDES Use for Entities Not Required to Obtain a GIIN

F1. How do I submit the FATCA XML Schema if I am a U.S. Withholding Agent (USWA), Territory Financial Institution (TFI), third party preparer, or other entity that is not required to have a GIIN?

F2. How do I complete the FATCA XML Schema if I am a U.S. Withholding Agent (USWA) or Territory Financial Institution (TFI)?

F3. How do I complete the FATCA XML Schema if I am a third party preparer or other entity that is not required to have a GIIN?

F4. Does IDES validate that a third party is authorized to submit on behalf of an FI?

F5. When a third party prepares the package, do they use their own digital signature or the digital signature of the entity for whom they are preparing the package?

F6. If a third party submits a package on behalf of an FI, who would receive alerts and be able to download notifications related to the payload?

F7. I am a third-party tax preparer. The tax authorities in my country have indicated they have elected Model 1 Option 2 for FATCA Reporting. How may I enroll to use IDES to transmit FATCA reporting information?

F8. I am a third-party tax preparer located in a Model 1 IGA jurisdiction. I am responsible for reporting on behalf of clients in Model 2 IGA and non-IGA jurisdictions. I obtained a FIN but IDES will not accept my enrollment. How can I enroll in IDES?

F9. How do I identify a U.S. entity as the controlling U.S. specified person?

F10. The FATCA General FAQ states that a Sponsored Entity does not need to provide its own GIIN until January 1, 2016 and is not required to register before that date. We received an error notification that “TIN not populated”, when the ReportingFI/TIN data element under the Reporting FI Group is left empty.

F11. I received a “missing City/Town” error code that describes the “City or town not populated”. What are the validation rules for <AddressFree> and <AddressFix>?

F12. We are a Sponsoring Entity and recently registered and received GIINs for several Sponsored Entities via the FATCA Online Registration System. How does a Sponsored Entity enroll in IDES?

F13. The FATCA General FAQ states that a Sponsored Entity does not need to provide its own GIIN until January 1, 2017. We received an error notification that “TIN not populated”, when the ReportingFI/TIN data element under the Reporting FI Group is left empty.

F14. I am filing a Form 8966 on behalf of a Passive NFFE. As a NFFE, it does not have, and is not required to obtain, a US TIN. How do I report a TIN for this entity if they don’t have one?

F15. We are a reporting Model 1 FFI. We maintain preexisting accounts that are U.S. reportable accounts where we have been unsuccessful in obtaining a U.S. TIN from the account holder. May we continue to use nine zeroes in place of a U.S. TIN when we report information in 2018 on that account with respect to the 2017 year?

FATCA IDES Technical Support

Pre and Post Transmission Related Questions

Additional Support

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General Questions

A1. What is the International Data Exchange Services (IDES) system?

System that allows IRS to exchange tax payer information with foreign tax authorities. An overview of data transmission to the IDES system is currently available on the IRS website at FATCA International Data Exchange Resources and Support Information (IDES).

Updated: 02-20-2015

A2. What is the International Compliance Management Model (ICMM) system?

System that allows IRS to send/receive, process, store, and manage FATCA data received from various sources to support needed compliance activities.

Updated: 02-20-2015

A3. What is the difference between an IDES Alert and an ICMM Notification?

IDES issues email alerts via unsecured, plain-text email and they contain information about the transmission processing within the IDES system. An ICMM Notification is a “transmission” file archive that contains encrypted documents that are sent from the United States Internal Revenue Service (IRS) to a Foreign Financial Institution (FFI), direct reporting non-financial foreign entity (NFFE), or Host Country Tax Authority (HCTA) in response to the transmission of a FATCA Report submitted on the Intergovernmental FATCA XML Schema or the paper Form 8966.

Added: 05-08-2015

A4. What is the frequency of IRS request for information on recalcitrant accounts?

The transmission can occur on the ad-hoc basis as HCTA receives the information from FFIs, or the HCTA can provide a single submission at or before the submission date and time as specified in the IGA. This applies to all jurisdictions.

A5. What is IRS expectation for HCTA response to request for information on recalcitrant accounts?

Standards for request and/or response to information requests are defined in the IGAs and the Competent Authority Arrangement (CAA).

Updated: 02-20-2015

A6. What are IRS standards for HCTA data validation on recalcitrant accounts through the FATCA XML schema?

All data provided should fully comply with FATCA XML schemas posted on IRS.gov. The schema user guides describe fields that are mandatory for FATCA reporting.

Updated: 02-20-2015

A7. How can HCTA and FFI obtain information as to system development progress and status?

The IRS publishes this information on the FATCA site on IRS.gov making it universally available at the same time. Additionally, users can subscribe to the FATCA newsletter for updates on the latest IRS news, guidance, regulations and other public information related to FATCA.

Updated: 02-20-2015

A8. What types of technical support will be present during integration testing? How will the HCTAs, direct reporting NFFEs, and FFIs report issues with integration testing back to the IRS?

The IDES vendor will provide help desk support under their contract with the IRS during testing to address technical issues related to the use of IDES. For testing related issues, the IDES Help Desk can be reached at testing@ides-support.com. If you have any particular issues related to data preparation, you can submit an email to lbi.fatca.ides@irs.gov.

Updated: 06-08-2015

A9. What is the protocol for HCTAs to contact the IRS with technical issues or questions regarding IDES?

The IDES vendor will be responsible for resolving technical issues or questions regarding IDES. The IDES Help Desk can be reached at 1-800-613-IDES (4337), 605-271-0311, or via email at questions @ides-support.com.

Updated: 02-20-2015

A10. What is the protocol for HCTAs to contact the IRS with issues or questions regarding reporting requirements?

The HCTA should direct questions regarding reporting requirements to the United States Competent Authority.

A11. When can I enroll to use IDES?

The IDES enrollment site is now open and can be accessed at IDES Enrollment. For HCTAs, once you receive your enrollment letter from the IRS, it will include HCTA-specific instructions to enroll.

Updated: 02-20-2015

A12. Does an HCTA need to get a GIIN?

No, GIINs are specific to Financial Institutions, Direct Reporting NFFEs, and sponsoring entities. However, when an HCTA enrolls, they will receive a FATCA Entity ID Number, which resembles a GIIN. For example, the FATCA Entity ID Number of the IRS is 000000.00000.TA.840.

Added: 02-20-2015

A13. Will an API or standalone application be available to assist with data preparation?

IDES will not be providing an API or application for data encryption and transmission. The file format has been described and the file preparation guide has been published on IRS.gov to assist users. There are currently samples of Data Preparation code available on GitHub in the IRSgov repository.

Updated 07-14-2015

A14. I am a Sponsoring Entity located in a Model 1 IGA jurisdiction. I am responsible for reporting on behalf of entities in Model 2 and non-IGA jurisdictions. When I attempt to enroll in IDES the system rejects my enrollment as coming from a Model 1 IGA jurisdiction. How can I use IDES as required to submit FATCA Reports?

The IRS developed a process that allows you to use IDES. You will obtain a second GIIN that reflects that you are located in a Model 2 or non-IGA jurisdiction.

1. Enter the IRS Registration Portal and create a new account.

2. Select the Financial Institution Type, Sponsoring Entity and click Next to continue.

3. Complete other questions and proceed to Part 1, Questions 3A-4.

4. Complete the application and other entries as you did originally.

After the approved GIIN appears on the FFI List, use the GIIN to enroll in IDES. Detailed information on IDES enrollment process can be found at https://www.ides-support.com/.

Updated: 07-28-2015

A15. What are the differences between the FATCA XML Schema v1.0 and Form 8966 for “rounding off to the whole currency amount”?

The general guidelines for rounding are the same in the instructions to Form 8966 and the schema. In the instructions to Form 8966, you may round fractional currency amounts up (or down) to the closest non-fractional (whole) currency amount. If you choose to round currency amounts, you must round all currency amounts reported. The schema defines the format of the money amount; it does not address the general accounting practices to round off to the whole amount.

The schema allows whole numbers and decimal numbers with 2 fraction digits (e.g. 12345, 12345.76 and 12345.7 are valid amounts). If an amount has more than 2 fraction digits, the amount will be invalid (e.g. 12345.768 is invalid amount).

Added: 07-14-2015

A16. We have heard previous discussions that there would be an updated XML Schema for FATCA Reporting (Form 8966) for 2015. Could you advise when we will have the new version?

The IRS released a draft version for FATCA XML Schema v2.0 in June 2016. This version will be deployed into production in January 2017. The IRS will conduct open user testing for all FATCA filers in Fall 2016. For more information, go to FATCA XML Schemas and Business Rules web page.

Updated: 08-10-2016

A17. I am a Direct Reporting Non-Financial Foreign Entity (NFFE) located in a Model 1 IGA jurisdiction. I am responsible for reporting to the IRS on substantial U.S. owners under the FATCA regulations. When I attempt to enroll in IDES, the system rejects my enrollment as coming from a Model 1 IGA jurisdiction. How can I use IDES as required to submit FATCA Reports?

The IRS developed a process that allows you to use IDES. You will obtain a second GIIN that reflects an "Other" country/jurisdiction of residence instead of a Model 1 IGA jurisdiction.

1. Enter the IRS Registration Portal and create a new account.

2. Select the Financial Institution Type "Single" and click Next

3. Complete other questions and proceed to Part 1, Questions 3A-4.to continue.

4. Complete the application and other questions as you did originally.

Additional information on the registration process can be found at FATCA Foreign Financial Institution Registration Tool. After the approved GIIN appears on the FFI List, use the GIIN to enroll in IDES only. When you complete the FATCA XML Schema, enter the GIIN that reflects your actual country/jurisdiction of residence for tax purposes in the "TIN" data element for ReportingFI. Detailed information on IDES enrollment process can be found at https://www.ides-support.com/.

A18. In the case of a Model 1 Option 2 (M1O2) arrangement, will a FATCA report filed by a Direct Reporting NFFE via IDES be routed directly to the US IRS or it requires HCTA’s approval before it gets onward forwarded to the US IRS?

A Direct Reporting Non-Financial Foreign Entity (NFFEs) reports directly to the IRS rather than through their Host Country Tax Authority (HCTA). Under IRS business rules, all files uploaded by an FI in a M1O2 jurisdiction will be routed to the HCTA. When a Direct Reporting NFFE applies for its GIIN through the FATCA Online Registration portal it must specify its jurisdiction as ‘Other’ if it is located in a M1O2 jurisdiction. The GIIN assigned as a result of this registration option instructs IDES to route transmissions directly to the IRS and delivers transmission Notifications directly to the Direct Reporting NFFE and not to the M1O2 HCTA.

Added: 08-10-2016

System Availability and Design

B1. When will the IDES system be accessible for HCTA, direct reporting NFFE, and/or FFI use?

IDES is designed to be "always on" and available to receive files. The system will be unavailable during planned maintenance periods. Generally, maintenance is performed on Saturdays between 6 PM and midnight EST. Any additional outages will be announced on the FATCA IRS.gov website.

Updated: 07-14-2015

B2. What methods of file transfer are available for the IDES system?

The IDES system is intended to support both SFTP and HTTPS transfers.

B3. Is the IDES system IPv6 compatible?

No, IDES will be IPv4 compatible only at the current time. Information about IPv6 compatibility will be published at a later date.

B4. What information will be contained in the IDES Alerts?

Information on IDES Alert Codes.

B5. What information will be contained in the ICMM Notifications?

Information on ICMM Notifications can be found on IRS.gov at IRS FATCA Report Notifications. The IRS has recently published a user guide containing information on ICMM Notifications.

Updated: 03-03-2015

B6. How does an entity enroll for a testing window?

First, they need to be an enrolled user of IDES. When a testing window has been identified, all enrolled users will receive an email notifying them of the window as well as instructions for signing up for that specific window. Additional information regarding testing can be found on the IRS.gov website.

Added: 03-03-2015

B7. When will the IDES system be accessible for testing purposes?

The IRS conducts periodic testing of IDES. Dates for testing windows will be made available at IDES Test Schedule.

Updated: 07-14-2015

B8. I have not received an expected email about IDES enrollment. Are there any known issues related to this?

Please make sure that you're email spam filter will accept emails from the IDES enrollment site (@ides-support.com). This is not only important for the enrollment email, but IDES Alerts.

Added: 02-20-2015

B9. How do I enroll for testing?

All those that are registered users with IDES will receive an email that provides details for the upcoming testing window. The email will include the start and end date of the window as well as the URL for that specific window. If you are an enrolled IDES user, you will be enrolled in the testing window.

Added: 07-14-2015

B10. What is the URL for accessing the test environment?

The URL is different for each testing window. The URL will be included in the email to registered IDES users alerting them of the upcoming test window.

Added: 07-14-2015

B11. During the Global IT Technical Forum call you indicated the IRS was preparing a maintenance release at the end of April that would address several reported defects. Could you inform us exactly what issues are being corrected?

The April 2016 maintenance release addressed the following issues:

Updated: 08-10-2016

B12. What is the procedure for reporting accounts with nil payments, such as a payment of zero or a negative balance? For example, a depository account may be held by a US Specified Person, have a positive account balance at 31 December, but have no payments of interest during the year.

In April 2016, the IRS updated FATCA Reporting to allow zero or negative amounts to be considered valid payment amounts. If you provide the Payment element by entering zero or a negative PaymentAmnt, you are required to enter value for the Type element also. Alternatively, you can submit the record without providing the Payment element. Both examples below are considered acceptable.

Example 1 — Zero payment amount and type:

Example 2 — No payment amount:

Added: 08-10-2016

Data Format and Structure

C1. What format should data be provided for the FATCA Report?

Data should be provided in the XML format, which complies with the Inter-governmental FATCA XML schema as agreed by the International Community and published on the IRS FATCA web site. See IRS Publication 5124 FATCA XML v1.1 User Guide.

C2. Is there a naming convention for files pertaining to IRS request for information on recalcitrant accounts?

No, there is currently no naming convention required at this time. If there is a change to this requirement, it will be published on the IRS FATCA web site.

C3. When will sample XML files related to FATCA submissions be available?

Sample XML documents for the FATCA NIL reports, sender metadata, and notifications have been uploaded to the IRS.gov website and can be found at FATCA XML Schemas and Business Rules for Form 8966. Additional sample XML packets are being developed and will be posted on IRS.gov as soon as available.

Added: 05-08-2015

C4. What is the format for sending metadata for file transfers to IDES (e.g., indicate a specific sender/receiver)?

Information regarding the metadata schema is documented in the IDES Metadata Schema User Guide, which can be found at IDES User Guide.

C5. Is the XML data based on UTF-8 character encoding?

Are there any restrictions on the range of characters that can be used? Yes, the FATCA XML schema v1.1 was developed using UTF-8. Additional specifications regarding acceptable characters can be found in the Competent Authority Arrangements.

C6. Is there a "not to exceed limit" on the size of the transmitted data file?

Is there a method to associate and/or merge files if transmission split due to size restrictions? At the current time, the maximum recommended file size is 200MB compressed. There is currently no method to merge files; this will be addressed at a later date if this becomes a recurring need. There is no need to associate the files, all the information can be sent in as many transmissions as needed.

C7. Within the XML schema, is the SendingCompanyIN data element used to determine the origin of the file?

The IRS will not rely on the SendingCompanyIN data element to determine the origin of a file. The Sender will be identified in the metadata that accompanies each IDES transmission.

C8. How will the DocTypeIndics reserved for testing purposes will be used in production and test environments?

There is a 'test' Doc Type Indicator in the schema that corresponds to each production indicator. It is expected all partners will make use of the 'test' doc type indicators during testing periods. The sender should not send data with ‘test” doc type indicators to IDES in production. Test data should only be transmitted to the test environment during test window.

Updated: 04-08-2015

C9. How will the IRS handle updates to the XML schema? Will the system still be able to accept older versions of the schema or will prior years' files need to be updated to the current schema version?

In June 2016, the IRS released FATCA XML schema v2.0 to be deployed in January 2017. FATCA Reporting will only accept XML files created using schema v2.0; multiple versions are not supported. All FATCA XML files should be created and validated using the current schema in effect at the time of filing. Prior to January 2017, use schema v1.1 for all FATCA submissions; after January 2017, only use v2.0 to amend, correct and void reports that were previously created using schema v1.1.

Updated: 08-10-2016

C10. If an individual has only received certain payment types, should the other payment types be listed with a zero amount or should they be omitted from the report for that individual?

If an individual has not received a particular payment type, zero amount is acceptable. If a particular payment type is not relevant to the individual, it is preferred that the information be omitted.

C11. What is the procedure for FFIs, direct reporting NFFEs, and HCTAs to verify test data prior to the launch of IDES?

The IRS will send Notifications regarding the submission of test files in the same way as in the production environment. If additional questions are generated after receiving a Notification, feel free to contact the IRS at the number indicated on the Notification.

Updated: 03-03-2015

C12. Can an HCTA create its own standard numbering format for the MessageRefID in the FATCA XML Schema for its financial institutions to use?

Yes. The only requirement is that the field be unique for each sender for the lifetime of the system and that it not exceed the maximum length of 200 characters.

Updated: 06-22-2015

C13. What is the difference between corrected, amended and void files?

• 'Corrected Data (FATCA2) is used for records being re-transmitted after the IRS has notified the sender of a problem with the file or underlying data. Corrected Data should ONLY be used when responding to an IRS request to correct the data.

• Amended Data (FATCA4) is used to amend a record(s) previously transmitted to, received and processed by the IRS, but is later found to contain erroneous information.

• Void Data instructs IRS to disregard previously-filed records when data needs to be re-transmitted. Please see IRS Pub 5124 for specific scenarios where this would be required. The original records should be re-transmitted with code FATCA3 which instructs IRS to void the original transmission. After voiding records, the revised records should then be transmitted to IRS with code FATCA1 as New Data.

Added: 05-08-2015

C14. When submitting a file with amended or corrected entries, what should be included in the MessageRefId field?

The MessageRefId should be a unique identifying number for the new file that includes the updated entries. The CorrMessageRefId should be the MessageRefId of the original file submission.

Updated: 06-22-2015

C15. How can HCTAs and filers ensure that the DocRefID they are using is unique across all reporting FIs ?

The DocRefID data element should be a unique identifier of a correctable item across all reporting financial institutions and reporting periods. To ensure the identifier is truly unique across all FFIs, beginning January 1, 2016, the IRS requires the following format rule to create the DocRefID.

• The data format is <reporting FI GIIN><period character (.)><unique value across all time for the reporting FI>

• The first part — <reporting FI GIIN> is the GIIN for the reporting FI associated with the reporting group

• The second part is a period character (.)

• The third part — <unique value across all time for the reporting FI> is an identifying value for the referenced record that is unique within the reporting FI for all time. Use of a GUID is recommended but not required.

This element should contain at least 21 characters, which includes the first part — reporting FI GIIN, the second part — period character (.), and at least one alphanumeric character to represent the third part. The maximum length of DocRefID is 200 characters.

DocRefID Examples:

Updated: 01-26-2016

C16. Are there any characters that are not allowed due to XML syntax rules and should be avoided in submitted XML documents?

The use of the ampersand (&) and less than (<) symbols as XML text content is not allowed by XML syntax rules. These characters must be replaced by predefined entity references “&amp;” and “&lt;” respectively. If the XML text content contains these prohibited characters, you will receive a failed schema error notification (XML not well-formed).

The use of the greater than (>), apostrophe (‘) and quotation mark(“) characters is not restricted by current SQL injection rules. To conform to XML schema best practices, these characters should be replaced by predefined entity references, “&gt;”, “&apos;” and “&quot;” respectively. For more information,, visit FATCA XML Schema Best Practices for Form 8966.

Updated: 08-10-2015

C17. Are there any characters that pose a security threat and should be avoided in submitted XML documents?

Previously the apostrophe (‘), double dash (--), quotation mark ("), and hash (#) symbols were prohibited due to a possible security threat. Currently the double dash (--), slash asterisk (/*) and ampersand hash (&#) character patterns are the only prohibited characters. To prevent file error notifications, do not include any of these character patterns.

Updated: 08-10-2015

C18. Can the restricted characters be included in escaped portions of the file (i.e. comments)?

Yes. Inclusion of any restricted characters will only cause a rejection if they are within the XML data elements. Restricted characters in escaped portions of the file, i.e. comments, will not cause a rejection.

Added: 04-08-2015

C19. Which users are permitted to submit pooled reports? What is the procedure for submission of these reports?

Pooled reports may not be submitted by HCTAs with respect to FIs in Model 1 jurisdictions. Pool reports may be submitted by FIs in Model 2 and Non IGA jurisdictions. Pooled reports are submitted using the same method as account reports. Pooled reports can be submitted using the FATCA Schema and by selecting pooled report in the reporting group.

Added: 02-20-2015

C20. Which users are required to submit a Nil report? What is the procedure for submission of these reports?

Generally, only Direct Reporting Non-Financial Foreign Entities (NFFEs) and Sponsoring Entities’ reporting on behalf of a Sponsored Direct Reporting NFFEs are required to submit a Nil Report. A Nil Report is optional for all other filers. Also note that nil reporting may not be required by the IRS, it may be required by the local jurisdiction. Consult your local tax administration for more information. For more information, sample nil reports are available at FATCA XML Schemas and Business Rules for Form 8966 web page.

Updated: 08-10-2016

C21. We're receiving a Notification that there are restricted characters in our file but when we check the FATCA XML Schema (Form 8966) we don't find any. What is wrong?

The IRS has noted that some signature tools may insert illegal characters in the KeyInfo element when generating a signature. If so, the KeyInfo element should be removed before submitting the package. The package will validate without it. Also check the updated guidance around restricted characters, referenced in FAQ C17. There has been recent change in the guidance and apostrophes, even in entity reference form, will cause a Failed Threat Detection Notification.

Updated: 07-14-2015

C22. How do I void a record reported in error using FATCA XML Schema?

To void a record:

• A FATCA Report must include an Account Report and/or a Pool Report.

• Typically a record is equivalent to one paper Form 8966. A record is an account report and/or pool report, plus the associated organizational filer. The filer may be a Reporting FI, Sponsor or Intermediary.

• A Reporting FI cannot be voided, amended or corrected alone. Only a whole record including AccountReport, PoolReport and ReportingFI, Sponsor (if present), can be voided.

• All fields in the void record must equal the same values as the original record previously submitted.

MessageSpec: Identify all corrected messages.

<MessageRefId>	Generate unique value
<CorrMessageRefId>	Original <MessageRefId> from original FATCA Report (minOccurs="0" maxOccurs="unbounded")

FATCA Report: Identify the data type in the <DocSpec> element for each applicable section, such as ReportingFI, Sponsor, Intermediary, AccountReport, and/or PoolReport

<DocTypeIndic>	FATCA3
<DocRefId>	Generate unique value using <ReportingGIIN>. <Value>
<CorrMessageRefId>	Original <MessageRefId> from original transmission
<CorrDocRefId>	Original <DocRefId> from the record being voided

Added: 09-09-2015

C23. How do I amend a FATCA Report using FATCA XML Schema?

To amend a record:

A FATCA Report that was previously processed by the IRS, but later found to contain record level errors, can be amended. For electronic filers, you are not required to void and amend the same record.

MessageSpec: Identify all corrected messages.

<MessageRefId>	Generate unique value
<CorrMessageRefId>	Original <MessageRefId> from original FATCA Report (minOccurs="0" maxOccurs="unbounded")

FATCA Report: Identify the data type in the <DocSpec> element for each applicable section, such as ReportingFI, Sponsor, Intermediary, AccountReport, and/or PoolReport

<DocTypeIndic>	FATCA4
<DocRefId>	Generate unique value using <ReportingGIIN>. <Value>
<CorrMessageRefId>	Original <MessageRefId> from original transmission
<CorrDocRefId>	Original <DocRefId> from the original record

Note: A FATCA report should contain similar <DocTypeIndic> elements in the same file. Do not combine void, amended and corrected records in the same file.

Added: 09-09-2015

C24. The FATCA XML Schema v1.1 does not allow us to report a Substantial Owner as an organization. There is no place in the schema to populate a name. Should we place the organization name in the Last Name field?

The IRS has created a new workaround for the TY 16 schema for organization to allow entities or organizations to be reported as substantial owners. Beginning in TY 2016, to report an entity as the substantial owner use the First Name field to specify the name of the entity or organization and use the Middle Name field to indicate “ENTITY2015” that the filer intends to report the entity as the substantial owner. This new workaround is strictly optional for TY2015 reporting. For further guidance on how the term substantial owner is defined by entity type, please refer to the Schema User Guide.

Updated: 03-29-2016

C25. In 2016, I submitted a new Form 8966, FATCA Report, using the XML Schema v1.1. In 2017, I need to amend or correct a record on that report using XML Schema v2.0. What version of the schema do I need to use to amend or correct the record?

Beginning January 16, 2017, FATCA Reporting will only support the XML schema v2.0. All new, nil, amended, corrected, and void reports should use version 2.0. The two versions of the FATCA XML schema are not backwards compatible and files submitted using schema version 1.1 will not validate against version 2.0. Example: In November 2016, a user submits Report2015 and receives a notification to correct record level errors within 120 days. In February 2017, the user should make all corrections using XML schema version 2.0.

Updated: 01-06-2017

C26. I submitted a file through IDES containing corrected records for TY 2014. I received a Notification that the IRS could not match the CorrDocRefID element with any existing record. At a recent IT Technical Forum call the IRS indicated this was due to the presence of duplicate DocRefIDs in the system for that tax year. How can I submit a corrected, amended or voided record for TY 2014 if that situation exists?

If there are duplicate DocRefIDs existing in the system, you may not be able to submit a corrected, amended or voided record in the usual process. The IRS has created the following workaround to submit the necessary changes: For all submissions under this procedure, use FATCA1 (New Data) as the DocTypeIndic. While we are aware this idenitifes a New record, for purposes of validation the use of FATCA1 will avoid the record being identified as a duplicate DocRefId. Prepare the record with a unique DocRefID (different than that used on the original record) according to the new DocRefID format.

For Individual Account Holders, enter the following in the MiddleName data element:

• For Corrected records, enter CORRECTTY2014

• For Amended Records, enter AMENDTY2014

• For Voided Records enter, VOIDTY2014

If you have a MiddleName to enter in that field you may enter it after the above language has been inserted in the field.

For Entity Account Holders, enter the codes (shown above) at the beginning of the entity Name field. You can enter the entity’s legal or business name following the specified language. For example, to correct a record for account holder "ABC Inc", enter “CORRECTTY2014 ABC Inc”.

Added: 08-10-2016

C27. I am reporting under a Model 1 IGA and want to report a NPFFI, how do I report the account type and account balance?

For tax years 2015 and 2016, NPFFI account reporting for aggregate amounts of payments made to such accounts are required. The Model 1 IGA does not require the reporting of an account balance of an account held by an NPFFI.

Summary	Description
Identify < AcctHolderType> “FATCA103”	Non-Participating FFI (NPFFI)
Report <AccountBalance> as zero “0”	Reporting for NPFFIs is not required under a Model 1 IGA; however, the account balance is a required element
Identify <Payment>
<Type> as Other “FATCA504”	The Type element is a required element with enumerations and it cannot be blank.
<PaymentTypeDesc> leave blank	Optional. This element is not used for reporting.
<PaymentAmnt> as zero “0”	The Payment Amount element is a required element and it cannot be blank.

Added: 11-30-2016

C28. What is the FilerCategory element? When may the FilerCategory be used?

The FilerCategory identifies the filer category code for a reporting financial institution and/or sponsor.

It is required based on specific filing status. For example:

• The FilerCategory element is mandatory for reporting financial institutions that are not a Sponsored FFI, Sponsored Direct Reporting NFFE, or Trustee-Documented Trust.

• The FilerCategory is mandatory if the report contains a Sponsoring Entity.

• Intermediaries are not allowed to use FilerCategory element.

In all other instances, the Filer Category element is optional. The FilerCategory element should not be used for 2014 or 2015 tax years.

Added: 03-22-2017

C29. When may the AccountClosed element be used?

The AccountClosed element permits financial institutions to declare the account status as closed or transferred during the calendar year. Do not report the account closed if an account holder rolls over the amounts in one account into another account with the same FFI during the calendar year. Withholding agents should not complete this element.

The AccountClosed element is optional. The AccountClosed element should not be used for 2014 or 2015 tax years.

Added: 03-22-2017

C30. When may the AccountNumber element be used?

The AccountNumber element provides the account number assigned by the financial institution to uniquely identify the account holder. The account number can be any of the following:

• A custodial account or depository account

• Code related to a debt or equity interest, not held in a custody account.

• Identification code of a cash value insurance contract or annuity contract.

Enter a “NANUM:

• Enter a “NANUM” for the element if the financial institution does not have an account numbering system.

• Enter a “NANUM” if the reporting FI is a withholding agent reporting a withholdable payment made to a payee that is not an account holder.

• Enter a “NANUM” if the reporting FI is a Direct Reporting NFFE.

The AcctNumberType attribute allows financial institutions to declare the uniquely used account number format. The value of the AcctNumberType attribute should be from the list below:

Values	Description of Account Number format
OECD601	IBAN	International Bank Account Number used in some countries to uniquely identify a customer's bank account
OECD602	OBAN	Other Bank Account Number
OECD603	ISIN	International Securities Identification Number uniquely identifies securities, such as bonds, commercial paper, stocks and warrants.
OECD604	OSIN	Other Securities Identification Number
OECD605	Other	Any other type of unique identifier codes or account number, i.e. insurance contract.

The AcctNumberType attribute is optional and is not required for FATCA reporting. The AcctNumberType attribute should not be used for 2014 or 2015 tax years.

Added: 03-22-2017

Data Transmission

D1. What are the procedures for sending files to IDES and/or ICMM systems?

All files will be submitted through IDES. IDES supports transfers through HTTPS and SFTP. Specific operational procedures for data preparation are documented in the IDES User Guide.

D2. What are the procedures for sending metadata for files to IDES?

Metadata files needs to be included in the transmission file submitted to IDES. Specific operational procedures for sending metadata files are documented in the IDES User Guide. Additionally, a sample metadata XML file can be found at FATCA XML Schemas and Business Rules for Form 8966.

D3. Will requests from the IRS for information on nonconsenting U.S. accounts and nonconsenting nonparticipating FFIs be transmitted via email?

No, all IRS requests for information will be transmitted via IDES. Format of the message exchange between IRS and HCTA will be via PDF

Updated: 03-03-2015

D4. Will IDES be used for transmitting the ICMM notifications?

Yes, IDES will be used as the transmission path for ICMM Notifications. A message type in the metadata will be used to distinguish Notifications from FATCA Reports.

D5. How will reciprocal data from the IRS be sent to an HCTA and in what format?

The data will be sent through IDES. The format of the XML specification is the same as the Form 8966 XML schema published on the IRS website and can be found in the IRS Publication Intergovernmental FATCA XML Schema v1.1.

D6. How will the HCTA notify IDES of outages of their systems that will be receiving data?

The HCTA should direct information regarding system outages to the United States Competent Authority.

D7. What is the procedure for sending corrected and/or amended data to receiving HCTA? Will the resubmission need to include only the corrected/amended entries or will the entire report need to be resubmitted?

Procedure for submitting corrected or amended data will be the same as the submission of a new report. Specific operational procedures for data preparation are documented in the IDES User Guide. The resubmission will only include the corrected/amended entries, with a reference to the original report. Please refer to the FATCA XML User Guide for preparing corrected or amended reports.

D8. What required data validation should be done on the FATCA Report data prior to being submitted to IDES?

The FATCA Report data XML file must be validated against FATCA XML schema published on IRS site. IRS Publication 5124 FATCA XML v1.1 User Guide contains all information required to ensure data is valid within the report. The User Guide outlines which fields are mandatory as well as specific business rules for each data element.

D9. I uploaded a FATCA Report to IDES 3 days ago. I received an Alert from IDES via e-mail that my file was successfully uploaded, but I have not received a Notification back from the IRS about the status of my FATCA Report. What could be wrong?

The IDES alert of a successful upload is information about the transmission of your file. IDES alerts cannot provide information about the receipt and processing of your files by IRS ICMM. The IRS should issue an ICMM Notification for every FATCA Report that is successfully transmitted through IDES letting you know the status of your FATCA Report. You should always receive a Notification within 24 hours, and in most cases within a few minutes, of the IRS ICMM system receiving your file. However, the IRS has identified specific instances during testing where ICMM Notifications are not issued to filers when certain errors are present. In addition, the IRS has identified circumstances in which filers did not download their notifications before the 7 day retention period expired, and these notifications were deleted and are no longer available for download. The IRS is working to address and resolve these issues.

In the meantime, there are a few things you can do to maximize your ability to receive notifications sent to you, and to determine whether a notification has been sent to in response to your file. These are as follow:

• First, make sure that e-mail alerts from IDES are not blocked as SPAM by your own e-mail system. Your e-mail system may have deleted it or may have sent it to you SPAM inbox. If you have been sent an alert that a notification is present, but the alert email is blocked you may never be aware of the notification’s availability for download.

• Second, make sure your IDES User Profile is configured to allow IDES to send you e-mail alerts, including those regarding notifications. There is a box that can be set to either send or not send you email alerts. If you would like to receive email alerts, including those about notifications, make sure it is set to send e-mail alerts.

• Third, check your IDES inbox over the next 24 hours following the upload of your file to IDES to determine whether there is a Notification waiting for download. Even if you have not received an e-mail Alert, the Notification could still be in your folder ready for download. After seven days the notification will automatically be deleted from the system.

If you have checked your folder in IDES and there is no Notification present after 48 hours or longer since your file was uploaded successfully, an error types which is suppressing a notification from being sent may have been detected on your file. A few things to check that may help include the following:

• Making sure the digital certificate you are using for signature and encryption for FATCA data has not expired or been revoked by your Certificate Authority.

• Also, you should double check the Metadata XML file that is part of your data packet, to ensure all of the mandatory data elements are correct. In particular, please make sure that FATCAEntCommunicationTypeCd is set to “RPT”, and that the TaxYear is set to “2014.”

• Make sure all of the entries are correct. Did you indicate you were submitting a FATCA Report? Did you select the correct tax reporting year (it should be 2014)? Etc.

After you’ve checked these items, you should resubmit your file.

Updated: 05-08-2015

D10. What if I have mistakenly submitted my FATCA Report production files to the FATCA Report test environment?

It is possible that you submitted your FATCA Report production files to the FATCA Report test environment instead of to the FATCA Report production environment. Any production files that are submitted to the test environment will not be processed and will need to be re-submitted to the production environment. Please do not submit production files to the test environment. In addition, please do not submit test files to the production environment.

Added: 05-14-2015

D11. We're receiving an alert that there are too many files in package (RC026). What is wrong?

The data packet to be transmitted is an archive in.ZIP file format. For Model 1 and 2 IGAs, this packet should include 3 files (FATCAEntitySenderId_Metadata.xml, FATCAEntityReceiverId_Key, and FATCAEntitySenderId_Payload). For Model 1 Option 2 IGAs, the packet should have 4 files, all of those mentioned previously plus the HCTAFATCAEntityId_Key. You are receiving RC026 because for your respective jurisdiction, there are more than the 3 or 4 files in the data packet.

Added: 05-08-2015

D12. Can we get individual confirmation that our files were received and approved by the IRS?

This will be done via the notifications. The Valid File Notification lets you know that the IRS has determined that the referenced file is in a valid format. Individual records submitted within the file have been processed and any errors detected during processing are provided in the Error Details included. This notification should be received within 24 hours of receiving Alert RC001 (indicating file was successfully uploaded to IDES).

Updated: 09-09-2015

D14. I received an alert that the file I sent to the IRS via IDES was deleted after 7 days and not downloaded by the IRS. Please explain.

The IRS identified files that could not be automatically downloaded because the files may have contained an invalid date in the metadata file. Please ensure the metadata element <FileCreateTs> contains a valid timestamp in valid pattern; for example, do not use 00 as a month and do not use any future year.

Updated: 11-03-2015

Data Encryption and Security

E1. What type of data encryption should be used prior to XML data transmission?

A digital signature shall be applied to XML and Notification files, referred to hereafter as data files. FATCA digital signatures use the SHA-256 hashing algorithm in conjunction with the private key for the sending party who will upload the file to IDES. The private key corresponds to the public key (RSA 2048-bit) that is stored on IDES. Following the creation of a digital signature and compression, the data file is encrypted using the AES algorithm and a randomly generated 256-bit key. The AES key is stored in a separate file and encrypted using the receiving party's public key, which is obtained from IDES. Both the data file and the key file shall be combined into a single zip file along with a separate metadata file for transmission to IDES.

Updated: 07-14-2015

E2. What encryption standard will be implemented on the transmission path?

For the IDES web user interface, the user connects using a web browser and the HTTPS protocol, which in turn utilizes Transport Layer Security (TLS 1.2) to protect sensitive data during electronic dissemination across the Internet. Alternately, the end user can interface with IDES using SSH File Transfer Protocol (SFTP) which is based on Secure Shell (SSH) version 2.0 or higher.

Updated: 07-14-2015

E3. How will passwords and public keys be controlled for data transmission to IRS?

The public key of the IRS for the users will be available through IDES. Each user will have a unique password.

Updated: 06-02-2015

E4. Who is responsible for data transmission security via encryption?

Each user, to include both HCTA/FFIs and IRS, will connect to IDES using a secure transmission protocol and an encrypted session. More information can be found in the IDES User Guide.

E5. What type of data encryption is used for reciprocal data sent to a HCTA?

The encryption tools and processes are the same regardless of the direction of the transmission.

E6. What are the requirements for digital certificates?

During the FFI, direct reporting NFFE, and HCTA enrollment process, the digital certificate must be uploaded to the IDES website. IDES accepts eight digital certificate products from seven Certificate Authorities (CAs). A list of acceptable certificate authorities and products can be found at Digital certificates.

Updated: 07-14-2015

E7. Can the AES 256 key be re-used for subsequent data transmissions or does the key have to be different each time?

The AES key must always be considered a “one time use” key. Software of the IDES User Guide in response to inquiries regarding data preparation.

E8. Can the IRS provide additional detail regarding proper preparation of data for submission to IDES?

The IRS will continue to update the FAQ and the data preparation section of the IDES User Guide in response to inquiries regarding data preparation.

There are currently samples of Data Preparation code available on GitHub in the IRSgov repository.

Updated: 05-08-2015

E9. Who needs to obtain a digital certificate?

A digital certificate is required to complete the FFI, direct reporting NFFE, and HCTA enrollment process for IDES. Only the entity that prepares an encrypted file and uploads it to IDES needs to obtain an account on IDES, and therefore needs to obtain a digital certificate. The private key used to sign the XML file must correspond to the public key in the digital certificate used to enroll in IDES.

Updated: 07-14-2015

E10. Can a digital certificate be shared by multiple organizations?

A digital certificate is issued to a single organization. The digital certificate contains a public key. Sharing of the corresponding private key between organizations is a poor security practice and, as such, it is strongly discouraged.

Added: 03-03-2015

E11. If an FFI is submitting on behalf of other FFIs (i.e. a parent company submitting for its subsidiaries), does each entity need a certificate, or only the entity submitting the file?

Only the submitting entity needs to have a certificate.

Added: 04-08-2015

E12. How does an organization obtain an SSL certificate if it does not have a Fully Qualified Domain Name (FQDN)?

Of the digital certificate products which IDES will accept, there is one that is not an SSL certificate and therefore does not require the organization to have a FQDN. More information may be found at http://identrust.com/irs/fatca/index.html.

Updated: 03-03-2015

E13. Is the use of ides-gateway.com or ides-support.com an acceptable FQDN for obtaining a digital certificate for IDES?

No, the FQDN in question is the entity's FQDN, not the IDES FQDN.

Added: 03-03-2015

E14. If an entity has multiple domain names (e.g. different in each country, fund domain name vs. company domain name, etc.), is there any guidance on which domain name should be used for obtaining the certificate?

Whichever organization is planning on doing the actual filing, is the only organization that requires a certificate and that is the one whose domain name should be used for the certificate..

Updated: 06-22-2015

E16. Are there any recommended software packages that will be able to encrypt the.zip file containing the signed XML file, using AES 256 bit encryption with a randomly generated AES 256 bit key?

There are existing data preparation software packages on the commercial market; however, the IRS does not endorse any specific software packages. There are currently samples of data preparation code available on GitHub in the IRS.gov repository.

Updated: 03-29-2016

E17. During testing, we have experienced issues with decrypting the notification file. Are there any lessons learned or best practices that you can share?

The IRS has posted a variety of different methods for decrypting notifications on Github in the IRSgov repository.

Updated: 06-22-2015

E18. I received a CF acknowledgement message what should I do to identify and correct the error?

You should verify the certificate has not expired, been revoked, and is one of the certificate products approved for use by FATCA. Other types of SSL or organizational certificates are not allowed. If the certificate is invalid, correct and update the IDES Enrollment site with a valid certificate.

Added: 08-10-2015

E19. We heard the IRS is changing the AES encryption cipher mode used during data packaging. What is this change?

The encryption standard used by the IRS meets current ISO standard(s). We continuously evaluate encryption algorithms to improve data security. During a routine security review, the IRS decided to improve encryption by replacing the Electronic Code Book (ECB) cipher mode with the Cipher Block Chaining (CBC) cipher mode. CBC is a stronger algorithm for encrypting data and its adoption will improve the current secure data packaging process. CBC requires an Initialization Vector (IV) for data packaging. Review the IDES Resources web page for more information

Added: 03-29-2016

E20. How do we create an Initialization Vector (IV)?

Beginning July 9, 2016, the Initialization Vector (IV) is a 16 byte random number. An IV can be generated in code or your current data packaging software.

Added: 03-29-2016

E21. As part of the CBC cipher mode, how do we exchange the Initialization Vector (IV)? Effective date: July 11, 2016.

The current data packaging process uses the Electronic Code Book (ECB) cipher mode where the 32 byte AES key is encrypted with the IRS Public Key. The revised data packaging process uses the Cipher Block Chaining (CBC) cipher mode where the 16 byte Initialization Vector (IV) is concatenated to the end of the 32 byte AES key. The resulting 48 byte value (32 byte AES key and 16 byte IV) is then encrypted with the IRS public key. All data packets received from the IRS must follow the same data packaging process with the updated CBC cipher mode. For decryption, the data packaging process is reversed, with the 48 byte key file separated into a 32 byte AES key and a 16 byte IV. Review the IDES Resources web page for more information.

Note: You will receive a NKS (Incorrect AES-key size) error notification if you (1) use the ECB cipher mode (2) do not include the IV in the key file and/or (3) incorrectly concatenate the key and IV.

Updated: 05-27-2016

E22. When updating the public key certificate in IDES, how will it affect files that were recently uploaded?

There are two possible problems if a public key certificate is updated while the file exchange is in progress. (1) If an encrypted file is sent to IRS that has not been processed yet, then digital signature validation will fail because the public key obtained from IDES will no longer correspond to the private key used to sign the payload file. (2) If the IRS sends a Notification using the old public key certificate, and the Recipient updates the public-private key pair before they retrieve the Notification from IDES, then the Recipient cannot decrypt the AES key file unless they kept a copy of their old private key. To avoid either situation, it is recommended that you wait until you have received a Notification from IRS for all files uploaded to IDES for transmission to IRS. You should update your public key certificate after you have received a Notification. If this is not possible and situation No. 1 arises, then you should receive a Notification from the IRS related to the digital signature verification failure. If this occurs, you should then resubmit the file using the newest public-private key pair. If situation No. 2 arises, please send the request to the lbi.fatca.ides@irs.gov mailbox to have the Notification retransmitted.

Added: 05-27-2016

IDES Use for Entities Not Required to Obtain a GIIN

F1. How do I submit the FATCA XML Schema if I am a U.S. Withholding Agent (USWA), Territory Financial Institution (TFI), third party preparer, or other entity that is not required to have a GIIN?

Certain entities, such as USWAs, TFIs, or other third party preparers (not sponsoring entities) submitting information on behalf of another entity, are not required to register or to obtain a GIIN and, therefore, should not do so. USWAs, TFIs, and other entities that are not required to have a GIIN (“non-GIIN filers”) must follow the procedure, below, in order to obtain a FATCA ID number (FIN) that they will use in lieu of a GIIN to enroll in and use IDES (including submitting an Intergovernmental FATCA XML schema v1.1 (electronic Form 8966)).

The FIN, along with the associated identifying information that you provide, will be treated as return information by the IRS. This FIN and the associated information provided will be used by the IRS to validate the non-GIIN filer’s IDES enrollment and submission of files via IDES and for other FATCA purposes. The FIN, but not the associated information (such as your name), will be published on the Foreign Financial Institution (FFI) List to facilitate the IDES enrollment and your submission of files via IDES. For more information about the FFI List, see IRS FFI List FAQs.

Your published FIN will be accompanied by a generic name (e.g., “U.S. Withholding Agent 1”) on the FFI List, and publication of your FIN on the FFI List does not change your status for FATCA purposes. That is, having your FIN published on the FFI List does not make you an FFI, and the FIN does not serve any function related to withholding tax on payments under FATCA.

Note: In order to request a FIN, you must consent to the IRS’s publication of the FIN on the FFI List because the FIN is return information. Visit the IDES Resources page for more information.

Added: 05-08-2015

F2. How do I complete the FATCA XML Schema if I am a U.S. Withholding Agent (USWA) or Territory Financial Institution (TFI)?

If you are a USWA or TFI, you complete the FATCA XML Schema in the same manner as if you were a “ReportingFI”. In the “TIN” data element, make sure to use your U.S. EIN (or, if you are a TFI that does not have a U.S. EIN, use the EIN used by the relevant U.S. territory tax administration to identify the TFI).

Note: For additional information, please read FAQ Q2 under the “Reporting” section on the General FAQ page.

Updated: 07-14-2015

F3. How do I complete the FATCA XML Schema if I am a third party preparer or other entity that is not required to have a GIIN?

If you are a third party preparer (not a sponsoring entity) or commercial software vendor and you are submitting the FATCA XML Schema on behalf of another entity (or on behalf of several other entities), enter your FIN, which you obtained to enroll and use IDES, in (1) “SendingCompanyIN” data element in the FATCA XML Schema Message Header and (2) "FATCAEntitySenderID" data element in the FATCA XML Metadata Schema.

Note: For additional information, please read FAQ Q2 under the “Reporting” section on the General FAQ page.

Updated: 07-14-2015

F4. Does IDES validate that a third party is authorized to submit on behalf of an FI?

No, IDES does not perform a validation.

Added: 06-08-2015

F5. When a third party prepares the package, do they use their own digital signature or the digital signature of the entity for whom they are preparing the package?

As the entity performing the actual submission, the third party would use their own digital signature.

Added: 06-08-2015

F6. If a third party submits a package on behalf of an FI, who would receive alerts and be able to download notifications related to the payload?

The entity that submits the package will receive the alerts and notification.

Added: 07-14-2015

F7. I am a third-party tax preparer. The tax authorities in my country have indicated they have elected Model 1 Option 2 for FATCA Reporting. How may I enroll to use IDES to transmit FATCA reporting information?

You can request a FATCA Identification Number (FIN) to enroll in IDES and submit FATCA Reports. If you are reporting information to a Model 1 Option 2 (M1O2) jurisdiction, you MUST obtain a FIN where the last three digits correspond to the ISO Country Code for the M1O2 jurisdiction. If you are reporting on behalf of other jurisdictions, you should obtain a second FIN with the jurisdiction code of ‘Other’ to report for those other jurisdictions.

Please consult your local jurisdiction to determine if it has elected Model 1 Option 2 for FATCA reporting. Review the IDES Resources and FIN web pages for information about how to obtain a FIN and enroll in IDES.

Added: 07-14-2015

F8. I am a third-party tax preparer located in a Model 1 IGA jurisdiction. I am responsible for reporting on behalf of clients in Model 2 IGA and non-IGA jurisdictions. I obtained a FIN but IDES will not accept my enrollment. How can I enroll in IDES?

The general rule for FATCA is that reporting entities in Model 1 IGA jurisdictions do not report directly to the IRS, but instead report directly to their host country tax authority. IDES follows the business rules of the IGAs. In order to use IDES to report you, need to request a FIN that identifies your tax jurisdiction code as ‘Other’. Review the IDES Resources and FIN web pages for information on obtaining a FIN and enrolling in IDES.

Added: 07-14-2015

F9. How do I identify a U.S. entity as the controlling U.S. specified person?

The FATCA XML Schema v1.1 does not allow a controlling person to be an entity. A controlling US person must be a natural US person. This issue will be addressed in a future revision of the FATCA Reporting XML Schema.

Added: 10-28-2015

F10. The FATCA General FAQ states that a Sponsored Entity does not need to provide its own GIIN until January 1, 2016 and is not required to register before that date. We received an error notification that “TIN not populated”, when the ReportingFI/TIN data element under the Reporting FI Group is left empty.

The ReportingFI/TIN element should contain the GIIN of the Sponsoring entity. Until the sponsor entities can obtain their own GIIN, you should continue to use the sponsoring entity’s GIIN. Do not leave this field blank.

Added: 10-28-2015

F11. I received a “missing City/Town” error code that describes the “City or town not populated”. What are the validation rules for <AddressFree> and <AddressFix>?

The FATCA XML Schema v1.1 definition supports the representation of two types of addresses, using two distinct data elements <AddressFix> and <AddressFree>. There is also the ability to use <AddressFix> with supplemental <AddressFree>, which is optional.

• The <AddressFix> data element supports using 9 separate elements, listed below:

Of the supported data elements listed above, only the <City> data element is required. If a value for <City> is not provided, then a validation error will be communicated back to the submitter explaining that “City or Town Not Provided”.

Please note that while an empty <City> data element and a value containing only whitespaces will successfully pass schema validation, ICMM requires at least one non-whitespace character to be provided. In these cases, a validation error will be communicated back to the submitter explaining that “City or Town Not Provided”.

• The <AddressFree> data element supports a less structured representation of an address. In this representation, the address is presented as one string of bytes, where various delimiters could be used to separate the various parts of the address.

There are no validations performed on the data provided in the <AddressFree> data element.

Updated: 12-10-2015

F12. We are a Sponsoring Entity and recently registered and received GIINs for several Sponsored Entities via the FATCA Online Registration System. How does a Sponsored Entity enroll in IDES?

The Sponsoring Entity agreed to perform the due diligence, withholding, and reporting obligations of one or more Sponsored Entities pursuant to Treas. Reg. §.1471-5(f)(1)(i)(F). The Sponsoring Entity should continue FATCA reporting on behalf its Sponsored Entities. Sponsored Entities CANNOT enroll in IDES.

The Reporting FI GIIN field in the Form 8966 will contain the Sponsored Entity’s GIIN. The Sponsor GIIN would be the Sponsoring Entity’s GIIN. If the Sponsoring Entity actually submits the file to IDES (as opposed to a third-party acting on their behalf) then their GIIN would also be present in the SendingCompanyIN Data Element in the Message Header.

Added: 12-10-2015

F13. The FATCA General FAQ states that a Sponsored Entity does not need to provide its own GIIN until January 1, 2017. We received an error notification that “TIN not populated”, when the ReportingFI/TIN data element under the Reporting FI Group is left empty.

The ReportingFI/TIN element should contain the GIIN of the Sponsoring entity. Until the sponsored entities can obtain their own GIIN, you should continue to use the sponsoring entity’s GIIN and do not leave this field blank. You should use the Sponsored Entity’s own GIIN to populate the ReportingFI/TIN starting January 1, 2017.

Added: 01-26-2016

F14. I am filing a Form 8966 on behalf of a Passive NFFE. As a NFFE, it does not have, and is not required to obtain, a US TIN. How do I report a TIN for this entity if they don’t have one?

A Reporting FI that is not obligated to have a US TIN or GIIN should leave the Reporting FI TIN element blank. This will cause a Record-Level Error Notification; however, because the absence of a TIN in this NFFE example is correct, the Notification does not require a Correction. Do not substitute any other characters for the TIN in this case.

If the TIN element was left blank due to the transition rule for Model 1 IGA filers reporting on pre-existing accounts, please see IDES FAQ A17 for more information.

Added: 02-09-2017

F15. We are a reporting Model 1 FFI. We maintain preexisting accounts that are U.S. reportable accounts where we have been unsuccessful in obtaining a U.S. TIN from the account holder. May we continue to use nine zeroes in place of a U.S. TIN when we report information in 2018 on that account with respect to the 2017 year?

No. Prior to 2017, Article 3(4) of the Model 1 IGA provided that a reporting Model 1 FFI was not required to report a U.S. TIN for the account holder of a preexisting account if the TIN was not in the FFI’s records; instead, the FFI could report the account holder’s date of birth if the date of birth was in the FFI’s records. The IRS published an FAQ to explain how to report an account holder for which the FFI did not have a TIN (i.e., either entering nine zeros or omitting the TIN and receiving an error message that should be ignored). See ICMM FAQ Q9 for updated rules for complying with Article 3(4) for reporting in 2017 with respect to the 2016 year.

Article 6(3)(b) of the Model 1 IGA provides that by January 1, 2017, the Model 1 jurisdiction commits to establish rules requiring reporting Model 1 FFIs to obtain U.S. TINs for preexisting accounts for reporting with respect to 2017 and later years. Beginning January 2018, the IRS will update its record validation rules so that error notifications will be sent if a reporting Model 1 FFI reports nine zeros as the TIN for an account holder.

If you have questions regarding the obligations under the IGA between the U.S. and your jurisdiction, or any domestic legislation passed to implement the provisions of the IGA, please contact the office of the Competent Authority in your jurisdiction.

Added: 04-11-2017

Pre and Post Transmission Related Questions

If you need immediate assistance, contact IDES Customer Support.

If you have additional questions about the International Data Exchange Service, please submit your question.

The IDES Webpage and IDES FAQs are updated on a regular basis with information related to IDES and with answers to IDES questions. However, you may submit a question here if you do not find the information you need elsewhere. Due to the volume of questions received, the IRS is unable to provide personalized responses, but answers to the most frequently asked questions will be posted periodically.

Additional Support

FATCA Help:

Additional FAQs are available for the FATCA Registration System, FATCA — FAQs General, FATCA FFI List, FATCA — Form 8938 FAQs, and FATCA — IRS Report Notification FAQs

Page Last Reviewed or Updated: 11-Apr-2017