16.06.2023

5'

FIRE System Update (2)

We would like to inform that the IRS recently announced eagerly anticipated relief regarding accessing the Information Returns Application for Transmitter Control Code (IR-TCC) System (which is used to request and manage TCCs), as well as the File Information Returns Electronically (FIRE) System (which is used to file information returns), and also informed about other platforms that will be used by filers in the future.

Since there are now numerous systems in place and as these systems are undergoing significant changes in them, please feel free to contact us if you have any questions. If you encounter difficulties in setting up your own access, we can act for you as a transmitter. For additional guidance, please also refer to our previous information.

In short, the IRS announced the following:

In summary, the situation is as follows:

It is encouraging that the IRS has recognized the challenges that Non-US entities and Non-U.S. Financial Institutions have with accessing the systems and is working on solutions. It is important to note, however, that the IRS has only granted an extension to access the FIRE system so far. We do not know how the proposed solution to access the system(s) will look like and we do not know for which systems the proposed solution will apply to. We are hopeful that the solution is pragmatic, will not require users to request US TINs, and will be used for all four systems that are in scope (IR-TCC, FIRE, IRIS and MeF).

Given the complexity of the various systems and user access accounts involved, numerous clients of ours, including QIs and other filers, have chosen to utilize our services as a third-party transmitter. With the appropriate authorization, we already have the capability to submit Forms 1042-S and 1099 on behalf of our clients, enabling us to effectively manage the IR-TCCFIRE, and IRIS systems on their behalf.