[FATCA IDES Technical FAQs; June 22, 2015, June 25, 2015]
Data Format and Structure
C12. Can an HCTA [Host Country Tax Authority -Ed.] 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.
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.
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, the IRS will be requiring the following format rule for creation of the DocRefID beginning October 1, 2015. Until that time (i.e. for files submitted up through September 30, 2015), the IRS will accept DocRefIDs that comply with either the old DocRefID or this new format. This transition period will allow those who want to begin using the new DocRefID rules to begin using them now to ensure uniqueness amongst FFIs, but it will not force those who prefer to continue using the old DocRefID rules to adopt the new rules until October 1, 2015.
- 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.
Data Encryption and Security
E15. 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..
E18. 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.
IDES Use for Entities Not Required to Obtain a GIIN
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 reporting with respect to calendar year 2014, a third party preparer or commercial software vendor filing on behalf of an entity with a filing deadline of March 31, 2015, has until June 29, 2015, to submit the FATCA XML Schema. For additional information, please read FAQ Q2 under the “Reporting” section on the General FAQ page.
F6. 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.
F7. 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.