New Foreign Filer TCC Registration System
To address this issue, the IRS has introduced the Foreign Filer TCC Registration System.
The new system allows eligible foreign filers whose authorized users do not have a U.S. SSN or ITIN to:
- create a Foreign Filer TCC account and obtain a Foreign Filer ID;
- complete the registration process to obtain a TCC Global Intermediary Identification Number (TCC GIIN);
- request a TCC once the TCC GIIN has been issued; and
- enrol in the International Data Exchange System (IDES) to transmit information returns electronically, including Forms 1042-S, applicable Forms 1099 and other information returns.
This provides a dedicated registration pathway for foreign organizations that would otherwise face difficulties accessing the standard IRIS process.
Access to the Foreign Filer TCC Registration System requires signing in via Login.gov or ID.me. If the user does not already have an account with one of these providers, one can be created directly from the Foreign Filer TCC Registration System homepage.
The email address used for Login.gov or ID.me must match the account email address of the responsible officer or point of contact on the Foreign Filer TCC Registration account.
Important distinction
The Foreign Filer TCC Registration System is not an alternative filing route for all foreign filers.
It is intended only for foreign filers whose authorized users do not have a U.S. SSN or ITIN.
Foreign filers whose authorized users do have a U.S. TIN must not use the Foreign Filer TCC Registration System. Instead, they are required to apply for a TCC through the standard IRIS Application for TCC and transmit the applicable information returns through IRIS.
It should also be noted that this new registration process relates to the electronic transmission of information returns through IDES. Form 1042 itself continues to be filed separately through the Modernized e-File (MeF) platform.
Practical registration considerations
The IRS has also issued Publication 6167, Foreign Filer Transmitter Control Code (TCC) Registration – Quick Steps, which provides practical guidance on the registration process.
Before starting the registration, affected organizations should gather the relevant information, including:
- the organization’s official legal name;
- mailing address;
- Employer Identification Number (EIN);
- responsible officer details;
- point of contact information, where applicable;
- credentials for signing in via Login.gov or ID.me; and
- access to the email account linked to the responsible officer or point of contact.
The legal name used for registration must match the name associated with the EIN.
Organizations should also ensure that the email address used for Login.gov or ID.me matches the email address of the responsible officer or point of contact listed on the Foreign Filer TCC account.
Once the Foreign Filer ID is issued, it should be recorded immediately, as it will be needed to access the account in the future.
The registration process includes the following main steps:
- setting up a Foreign Filer TCC account to obtain a Foreign Filer ID;
- completing and submitting the registration for a TCC GIIN;
- monitoring the message board for account updates and TCC GIIN approval messages;
- requesting a TCC once the TCC GIIN has been issued; and
- preparing for IDES enrolment.
After both the TCC GIIN and TCC have been issued, organizations should allow for a processing period of approximately 3 to 6 weeks before enrolling in IDES. IDES enrolment will also require the TCC GIIN and an Authorized Security Certificate from an approved Certificate Authority.
What should QIs and foreign withholding agents do now?
The launch of the Foreign Filer TCC Registration System removes one of the main obstacles previously identified for foreign filers preparing for the FIRE-to-IRIS transition.
Affected organizations should therefore no longer postpone their preparations and should ensure that they are ready for the 2027 filing season.
We recommend that QIs and other foreign withholding agents:
- determine whether their authorized users have a U.S. TIN, such as an SSN or ITIN;
- assess whether they should use the Foreign Filer TCC Registration System or the standard IRIS TCC application process;
- verify that the legal name used for registration matches the name associated with their EIN;
- identify the appropriate responsible officer and points of contact;
- ensure that the relevant Login.gov or ID.me access requirements can be met;
- review the practical steps set out in IRS Publication 6167 and gather the required registration information before starting the process;
- take into account the additional 3 to 6 week processing period before IDES enrolment once the TCC GIIN and TCC have been issued;
- prepare for the IDES enrolment requirements, including the need for an Authorized Security Certificate from an approved Certificate Authority;
- start the registration process in a timely manner; and
- continue preparing for the mandatory migration away from FIRE and towards the relevant IRS filing platforms for future information reporting.
How BDO can help?
BDO assists financial institutions, Qualified Intermediaries and other withholding agents with:
- assessing the impact of the IRS reporting changes;
- determining the appropriate registration and filing approach;
- supporting TCC registration processes and reporting readiness;
- preparing and reviewing the relevant forms for U.S. information reporting purposes; and
- managing the transition from FIRE to IRIS, IDES and other relevant IRS filing platforms.
Please reach out to your regular BDO contact if you would like to discuss how these changes may affect your organization.