[FATCA IDES Technical FAQs; July 14, 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.
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?
Note: In order to be able to use IDES ahead of the June extended deadline for submission of FATCA reports for Model 2 and non-IGA jurisdictions you will have to obtain your new GIIN by May 21, 2015.
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.
a. Question 3: Select Financial Institutions Country of Residence, Other.
b. Question 3B: Enter your Financial Institution’s country/jurisdiction tax ID, if available.
c. Question 4: Select the Financial Institution’s classification in its jurisdiction of tax residence, None of the Above.
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/.
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).
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.
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 atIDES Test Schedule.
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.
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.
Data Format and Structure
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.
D12. Can we get individual confirmation that our files were received and approved by the IRS?
This will be done via the notifications. The Interim Valid File Notification (NIM) indicates that the file is in a valid format. This notification should be received within 24 hours of receiving Alert RC001 (indicating file was successfully uploaded to IDES). Once record level validation is functional, further communication will be sent if errors are detected during record processing.
D13. I uploaded a FATCA Report to IDES 3 days ago and have not received a notification about the status of my FATCA Report. Does the XML format cause a problem?
The IRS has identified a specific scenario where notifications are not issued to filers when certain errors are present. A possible cause for a missing notification is XML that is not formatted and is contained on one continuous line. In this scenario, you can reformat the XML into an acceptable format using a variety of online tools, such as XML Pretty Print. The correctly formatted version of the XML can be resubmitted in a new data packet.
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.
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.
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.
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.
IDES Use for Entities Not Required to Obtain 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)?
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.
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.
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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.
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.