Luxembourg financial institutions should consider impact of temporary relief from reporting US TINs for certain accounts

For tax years 2022, 2023 and 2024, under Notice 2023-11, the United States (US) Internal Revenue Service (IRS) has announced that it will not require certain foreign financial institutions (FFIs) to furnish US tax identification numbers (TINs) for accounts preceding the effective dates of the Foreign Account Tax Compliance Act (FATCA) and associated Intergovernmental Agreements (IGAs).

To qualify for this temporary relief, FFIs must meet certain requirements.

To the extent the relief requirements …