FATCA and CRS

FATCA

• Why am I affected by FATCA / Why am I being written to?
• I have never heard of a TIN- what is it?
• I was born in the United States but have been a tax resident in Ireland my whole life- am I still considered a US citizen?
• I am a US citizen but do not have a US TIN in my possession and/or have never received a US TIN.
• I am US tax resident but do not want to provide a TIN
• I have changed my address to the US
• What happens if I open a joint account is where one person on the account is a US citizen and the other person is a non-US citizen? 
• Do I need to complete an Individual Self Certificate if I am opening a student account while studying for a short period of time in Ireland?
• What information is provided to Revenue?

CRS

• Why am I affected by CRS / Why am I being written to?
• I have never heard of a TIN- what is it?
• What happens if I advise PTSB of a change in my address to a non-Irish/non-US address?
• What happens if I open a joint account where one person on the account is a non-Irish/non-US tax resident and the other person is an Irish tax resident? 
• Can I open an account if I am non-Irish/non-US tax resident but do not want to provide a TIN?
• Do I need to complete an Individual Self Certificate if am opening a student account while studying for a short period of time in Ireland?
• If I open an account and wish to lodge funds into my account from a foreign investment or will get regular foreign dividends/bonuses or pensions will I need to complete a Self Certification?
• If I change my address to a foreign address/holiday home, do I need to complete a Self Certification?

Why am I affected by FATCA / Why am I being written to?

If an individual’s account information contains any of the following criteria, PTSB may need to request further information or documentation to determine if the customer is a Specified US Person under FATCA.

• US citizenship or US residence.
• US place of birth.
• US mailing or residence address (including US PO boxes).
• US telephone number.
• Standing instructions to transfer funds to a US address or an account maintained in the US.
• Current effective power of attorney or signatory authority granted to a person with a US address.
• ‘In care of’ or ‘hold mail’ address which is the sole address for the account holder.

If a customer is born in the US, they are considered a Specified U.S Person. If a customer has one of the other criteria listed above, PTSB may need to request additional information to determine if they are a Specified U.S. Person under FATCA.

Existing personal customers may also be asked to provide FATCA related information if there is a change of circumstance on a customer’s account(s) which may indicate a change in their status for FATCA reporting purposes (e.g. a change of address to or from a US address).

All new personal customers are required, as part of account opening procedures, to answer questions to confirm whether they are US citizens and resident for tax purposes in the United States. Using this information, PTSB can determine whether the customer is reportable or not for FATCA purposes.

Further information in relation to FATCA and CRS can be found on the Revenue website: https://www.revenue.ie/en/companies-and-charities/international-tax/aeoi/fatca/index.aspx

I have never heard of a TIN- what is it?

A TIN is a Tax identification number i.e., a social security number (e.g. Irish TIN is PPSN).

I was born in the United States but have been a tax resident in Ireland my whole life- am I still considered a US citizen?

A person born in the US is generally regarded as a US citizen and will need to complete the relevant FATCA questions. If you are a US citizen, we need you to provide us with a US TIN which is typically your social security number.

There are a couple of exceptions to this, 1) you may have renounced your US citizenship or 2) your parents were foreign diplomats. If you fall under these circumstances, you will need to provide documentation for these scenarios.

I am a US citizen but do not have a US TIN in my possession and/or have never received a US TIN.

You can apply to the IRS to obtain a US TIN. Further information on how to apply for a US TIN can be found at: https://www.irs.gov/individuals/international-taxpayers/taxpayer-identification-numbers-tin.

I am US tax resident but do not want to provide a TIN

If you have a US tax residency and do not provide us with a foreign TIN, you may be incorrectly included or excluded from PTSB’s FATCA/CRS information returns submitted to the Irish Revenue Commissioners. In you are opening an account with us in the above circumstances we cannot proceed with the opening of the account.

I have changed my address to the US

You will need to answer the relevant FATCA questions and an Individual Self-Certification form can be sent to your new address so we can ensure the tax information we hold for you is updated accordingly.

What happens if I open a joint account is where one person on the account is a US citizen and the other person is a non-US citizen? 

All parties on the account need to fill out a Self Certificate.

Do I need to complete an Individual Self Certificate if I am opening a student account while studying for a short period of time in Ireland?

Yes, you will need to complete an Individual Self-Certification form. You may not be a tax resident in another country however we are obliged as a financial institution to gather this information.

What information is provided to Revenue?

If you are deemed FATCA reportable, the following information is required to be submitted.

• Your name, address and United States Tax Identification Number (TIN);
• Your date of birth
• Your account number
• Your account balance or value at the end of the reporting period or at the date of closure (if your account was closed during the reporting period);
• The following amounts paid or credited to your account (depending on the account type) during the reporting period:
• With respect to deposit accounts, the total gross amount of interest;
• With respect to custodial accounts, the total gross amount of interest, dividends, other income and proceeds from the sale or redemption of property; and
• With respect to other accounts, the total gross amount paid or credited to the account including the aggregate amount of any redemption payments.

The reporting to each local tax authority will take the form of an annual FATCA return.

CRS

Why am I affected by CRS / Why am I being written to?

Existing personal customers may be asked to provide CRS related information If an individual’s account information contains any of the following criteria which may indicate that the individual could be considered tax resident in another country, PTSB may need to request further information or documentation to determine if the customer is reportable under CRS.

• identification of the individual as a resident of a CRS reportable jurisdiction;
• current (mailing, residence, post office box or c/o) address in a CRS reportable jurisdiction;
• one or more telephone numbers in a CRS reportable jurisdiction and no telephone number in the country of the reporting Financial Institution (e.g. a customer who has provided a Spanish telephone number for an account held with Bank of Ireland in Dublin, but no Irish telephone number);
• standing instructions (other than with respect to a depository account) to transfer funds to an account maintained in a CRS reportable jurisdiction;
• current effective power of attorney or signatory authority granted to a person with an address in a CRS reportable jurisdiction; and
• ‘hold mail’ instruction or ‘in care of’ address in a CRS reportable jurisdiction, which is the sole address for the account holder.

Having one of these criteria does not mean that a customer is CRS reportable, however in these circumstances PTSB may request additional information.

Also, existing personal customers may be asked to provide CRS related information if there is a change of circumstance on a customer’s account(s) which may indicate a change in their status for CRS reporting purposes (e.g. a change of address to or from an address in a CRS reportable jurisdiction).

All new personal customers are required, as part of account opening procedures, to answer questions to confirm whether they are resident for tax purposes in countries or territories other than the jurisdiction in which their accounts will be located. Using this information, PTSB can determine whether the customer is reportable or not for CRS purposes.

Further information in relation to FATCA and CRS can be found on the Revenue website: https://www.revenue.ie/en/companies-and-charities/international-tax/aeoi/fatca/index.aspx

I have never heard of a TIN- what is it?

A TIN is a Tax identification number i.e., a unique reference number issued by the issuing jurisdiction (e.g. Irish TIN is PPSN). 

What happens if I advise PTSB of a change in my address to a non-Irish/non-US address?

You will need to complete the relevant CRS questions and an Individual Self-Certification can should be sent to your new address so we can ensure the tax information we hold for you is updated accordingly.

What happens if I open a joint account where one person on the account is a non-Irish/non-US tax resident and the other person is an Irish tax resident? 

All account holders must complete a self-certificate.

Can I open an account if I am non-Irish/non-US tax resident but do not want to provide a TIN?

In the event you are looking to open an account with us in the above circumstances we cannot proceed with opening the account.

Do I need to complete an Individual Self Certificate if am opening a student account while studying for a short period of time in Ireland?

Yes, you will need to complete an Individual Self-Certification form. You may not be a tax resident in another country however we are obliged as a financial institution to gather this information.

If I open an account and wish to lodge funds into my account from a foreign investment or will get regular foreign dividends/bonuses or pensions will I need to complete a Self Certification?

No, source of funds does not require an Individual Self-Certification to be filled out.

If I change my address to a foreign address/holiday home, do I need to complete a Self Certification?

Yes you will need to complete an Individual Self-Certification.