Chapter 3 Temporary Regulations
Published on:
February 6, 2017
Submitted to:
Department of the Treasury and the Internal Revenue Service (IRS)
Submitted by:
SIFMA
SIFMA provided comments to the Department of the Treasury and the Internal Revenue Service (IRS) on Chapter 3 temporary regulations providing requirement for beneficial owner withholding certificates to include foreign TIN and date of birth. SIFMA is concerned by the January 1, 2017 effective date of the requirement for a beneficial owner withholding certificate to include the beneficial owner’s foreign TIN, and, for an individual, date of birth. Given that the regulations were published December 30, 2016, our members did not have sufficient time to update account opening documents to inform customers of this requirement, train personnel, or implement form validation procedures.
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