Reminder: New W-8BEN Rules
Friday, January 12, 2018 10:55 AM

For IRS W-8BEN forms obtained on or after January 1, 2017, you must collect a date of birth for the foreign credit union member.  However, if you have the foreign member’s date of birth in your files, you may use that information for reporting purposes and will not be required to treat a Form W-8BEN as invalid because it did not include a date of birth. 

Also, after January 1st, if you have an otherwise valid Form W-8BEN, but it is missing a foreign TIN, you are permitted to obtain the member’s foreign TIN on a written statement provided by the member (including a written statement transmitted by email) that indicates that the foreign TIN is to be associated with the member’s Form W-8BEN. Similarly, you are permitted to obtain the reasonable explanation for the absence of a foreign TIN in this manner.

For more information see the CUNA January 12, 2017 blog post: How the New FATCA Rules May Affect Your W-8BEN and 1042-S Reporting.

Source: CUNA Compliance Blog