have relinquished, or intend to relinquish, their U.S. citizenship in order to ease the tax
obligations that are part of the U.S. expatriation process. The procedures are available
to U.S. citizens with a net worth of less than $2 million and an aggregate tax liability of
$25,000 or less for the taxable year of expatriation and the five prior years. An
applicant for the relief is not required to obtain an SSN for purposes of using the
procedures and may use his or her best efforts in computing his or her total tax for each
year. The relief procedures are available at https://www.irs.gov/individuals/international-
taxpayers/relief-procedures-for-certain-former-citizens.
Notwithstanding the years of relief the Treasury Department and the IRS have
provided to reporting Model 1 FFIs that have not been reporting required U.S. TINs for
preexisting accounts, the IRS continues to receive reporting from Model 1 IGA
jurisdictions that does not include required U.S. TINs for all preexisting accounts that
are U.S. reportable accounts. Obtaining U.S. TINs from U.S. taxpayers connected to
accounts at FFIs, including accounts located in the taxpayer’s country of residence, is
crucial to ensuring that the IRS has the necessary information to determine whether
U.S. taxpayers are complying with their U.S. tax obligations. To better understand the
issues that FFIs were facing in obtaining required U.S. TINs, the IRS developed a series
of codes (TIN Codes) a reporting Model 1 FFI could use to populate the TIN field for
2020 data. The IRS shared the TIN Codes with each Model 1 IGA jurisdiction in early
2021 and then issued the TIN Codes in an FAQ on IRS.gov on May 13, 2021, available
at https://www.irs.gov/businesses/corporations/frequently-asked-questions-faqs-fatca-
compliance-legal. These TIN Codes indicated that a required U.S. TIN had not been