Instructions to reporting financial institutions on their obligations to report U.S. tax identification numbers
The Barbados Revenue Authority (BRA) in March 2025, issued Guidance Note OGC No. 09/2025, providing instructions to reporting Barbados financial institutions on their obligations to report U.S. tax identification numbers (TINs), ensuring compliance with FATCA.
Obligations in respect of pre-existing accounts
Per the guidance, reporting financial institutions are mandated under FATCA to report U.S. TINs for reportable accounts maintained as of June 30, 2014, provided that the U.S. TINs are available in their records. In the absence of U.S. TINs, reporting financial institutions must report the dates of birth of the specified U.S. persons, if found on record. Considering the challenges faced by foreign financial institutions in obtaining U.S. TINs for pre-existing accounts, the U.S. has introduced temporary administrative relief measures granted under IRS Notice 2023-11.
Obligations in respect of new accounts
For new accounts identified as U.S. reportable accounts and opened on or after July 1, 2014, reporting financial institutions are mandated to obtain the U.S. TIN on the Self-Certification Form during the onboarding process for all U.S. account holders or controlling persons. If the U.S. TIN was not captured during onboarding, the reporting financial institution must promptly initiate remediation actions to rectify this omission.
Read a March 2025 report prepared by the KPMG member firm in Barbados