On September 25, 2017, the IRS released Notice 2017-46 providing much anticipated official relief to foreign financial institutions (FFIs) facing requirements to obtain and report taxpayer identification numbers (TINs). Earlier this year, regulations were released under the Foreign Account Tax Compliance Act (FATCA) that require certain FFIs to report TINs to the IRS for foreign financial accounts held by U.S. taxpayers and foreign entities with U.S. owners. Under the regulations, each FFI was required to report this information to its taxing authority, which then must exchange the information with the IRS. Beginning with the 2017 tax year, the regulations stated that a FFI that did not include a reportable person’s TIN would be considered in significant non-compliance with FATCA and trigger a notice to the foreign taxing authority concerning such non-compliance. If the FFI did not remedy the lack of a TIN after such notice, the U.S. could treat the FFI as a “nonparticipating FFI” subject to 30% withholding under FATCA.