FATCA FAQs - Issues Involving U.S. Address or Telephone Number

FATCA related FAQs involving U.S. address or telephone number. See KB2601 for other FATCA related FAQ topics.


Q1: I received a notification that a review of my file indicated a U.S. address or telephone and additional information is required. What additional information do I need to provide?

A1: You need to provide one document from Category (A) AND one document from Category (B) from the table below AND a written explanation explaining the U.S. address.

Category (A)
Category (B)
Category (C)
ANY OF the following documents issued by a non-US country:
ANY OF the following documents that match your foreign address:
A reasonable written explanation supporting your claim of non-US status. 
·         Driver’s license
·         Driver’s license
·         Passport
·         Bank or brokerage statement*
·         National identity card
·         Utility bill*

*Bank or brokerage statements and utility bills must be less than 12 months old.


Q2: The day count table on the account application says I am a U.S. tax resident and will not let me complete IRS Form W-8. What should I do?

A2: The US Internal Revenue Service generally considers individuals who spend a significant number of days in the United States each year to be U.S. taxpayers. The table flags customers who exceed those IRS rules for U.S. income tax residency and requires a W-9. Alternatively, it may be possible for you to satisfy the “closer connection test” or utilize a U.S. tax treaty to avoid U.S. tax residency. Please refer to IRS Publication 519 for details or consult a tax professional regarding IRS rules for counting days, the closer connection test and U.S. tax treaties.


Q3: I am a studying in the U.S. and present on an F-1 visa. I responded to your email and provided a copy of my F-1 visa. I received an email saying my response was insufficient to resolve the issue. Why?

A3: Please check the expiration date of your visa. If your visa has expired, please provide other evidence of your status, such as an Optional Practical Training (OPT) card, a copy of Form I-20 endorsed by the DSO for your school or another Employment Authorization Document (EAD). Also confirm you submitted the necessary proof of identify and address documentation.


Q4: I use my daughter’s address to receive all mail. She lives in the United States. What should I do?

A4: In this case, you can probably satisfy the substantial presence test noted in the notification you've received . Please provide the number of days you spent or plan to spend in the U.S. in the current and prior two years (e.g., 2015, 2014 and 2013). Also refer to the documentation requirements outlined in FAQ#1 above.


Q5: The address or telephone you noted in your email is out-of-date. I have since moved out of the United States. What should I do?

A5: The fastest and most effective way to remedy the situation is to provide the information as requested in the notification you've received (see FAQ#1 above), so that our records are complete. You should also log into Account Management and make any required changes to your personal information of record.


We do not provide tax advice. Please consult your tax advisor for advice in completing tax forms and determining your taxpayer status.