The Latest IRS, FATCA and CRS News for October 2025

Australia: Extension of Temporary U.S. TIN Relief 

On October 27th, the Australian Taxation Office (‘ATO’) published an update regarding extension of temporary U.S. TIN relief for 2025, 2026, and 2027. To obtain this relief and avoid receiving a notice of non-compliance from the Internal Revenue Service (‘IRS’), Australian Financial Institutions should report certain pre-existing U.S. accounts with missing TINs as follows: 

• Obtain and report the date of birth of each account holder that is an individual and controlling person whose U.S. TIN is not reported. 

• Annually request from each account holder any missing U.S. TINs, providing relevent resources and instructions for obtaining a TIN. 

• Annually search electronically searchable data maintained by the Reporting Model 1 FFI for any missing required U.S. TINs.  

• Report an accurate TIN code for each account that is missing a required U.S. TIN. 

• If the FFI’s electronically searchable account information contains a foreign TIN (FTIN), or functional equivalent, assigned to a taxpayer by its country of residence, report an FTIN for each specified U.S. person that is missing a required U.S. TIN. DO NOT report Australian TFNs. If the ‘country issued by’ element is ‘AU’, the TIN field must be ‘NA’. The IRS has provided a list of jurisdictions that do not issue foreign TINs or where laws restrict the disclosure of TINs. 

• Use the AddressFix element to report the city and country of residence for each specified U.S. person with a missing U.S. TIN. 
• Retain records of relevant policies, procedures, and compliance actions until 2031 for potential review by authorities. 

Bahamas: FATCA and CRS Reporting Deadlines 

The Bahamas Competent Authority posted key dates regarding FATCA, CRS, and CbC reporting. The AEOI portal opened on Wednesday, October 1, 2025, at 9am EST and will close on Tuesday, March 31, 2026, at 5pm EST. The portal will reopen in July 2026 for 2025 tax reporting.  

Any financial institutions with FATCA, CRS, and CbC reporting obligations after the close of the portal in March should contact The Bahamas Competent Authority at helpdesk@taxreporting.finance.gov.bs or information@taxreporting.finance.gov.bs.  

Barbados: Guidance Note OGC No. 12/2025 

On October 21st, the Barbados Revenue Authority (‘the Authority’) issued Guidance Note OGC No. 12/2025, to provide clarity to Reporting Barbados Financial Institutions on the collection of tax identification numbers for new and pre-existing accounts. The notice represents an update to Guidance Note OGC No. 09/2023 issued by the Authority in November 2023.  

British Virgin Islands: CRS 2.0 and CARF Notice 

On October 23rd, the International Tax Authority (‘ITA’) of the British Virgin Islands posted a notice regarding CRS 2.0 and CARF.  

BVI intends to introduce CRS 2.0 with effect from January 1, 2026. This means that by the end of 2026, Financial Institutions must collect the new information and ensure that it is submitted to the ITA by May 2027.  

BVI has also committed to the implementation of the Crypto Asset Reporting Framework (‘CARF’). The commitment is for exchanges in 2028. 

United Kingdom: Updates to International Exchange of Information Manual 

The United Kingdom’s HM Revenue & Customs (‘HMRC’) updated the International Exchange of Information Manual (‘IEIM’) to include a new section, IEIM404510, Mandatory Registration.  

All Reporting Financial Institutions (‘RFIs’) and Trustee-Documented Trusts (‘TDTs’) must register for HMRC’s AEOI service by the later of December 31, 2025, or January 31 following the calendar year in which the entity first falls within the definition of Reporting Financial Institution or Trustee-Documented Trust, for either or both CRS and FATCA purposes. For Reporting Financial Institutions that are already registered for AEOI, no further action is required.  

Additional updates to this Mandatory Registration section include: 

• When registering a TDT, the TDT should be shown as the reporting financial institution, not the trustee. The reporting trustee should be named as the contact. 

• Registration is a single registration for AEOI covering both CRS and FATCA. Where an entity is in scope for either CRS or FATCA but not both, there is no requirement to notify HMRC which of the regimes the entity falls within. 

• Registration is a one-off requirement. Once an entity is registered for the AEOI service, it will remain registered for subsequent years unless it deregisters from the AEOI service. 

• If an entity registers and has no reportable accounts, there is no obligation to submit a nil return, though the entity may choose to do so.  

• Entities that are brought within scope by CRS 2.0, such as Electronic Money Institutions, will meet the definition of Financial Institution starting January 1, 2026. The registration deadline for such entities is January 31, 2027.  
• Financial Institutions that are taken out of scope by CRS 2.0, for example charities meeting the criteria to be Qualified Non-Profit Entities, may deregister from HMRC’s AEOI service from January 1, 2026. HMRC will accept that any such non-profit organization that has not registered with HMRC’s AEOI service because it has never had Reportable Accounts is not required to register by December 31, 2025.