We have some couples moving to the area for work. All legit. Worker has US ITIN or similar. Some spouses will not be working. They do not have a US number.....or should they have one? For example, joint ownership on a savings account.

How are you handling such cases for deposit accounts?

We are getting passports, etc. for CIP. Its the TIN issue that we are struggling with as regards the non-working foreign nationals that have moved here.

Does your policy address this issue? If opening an account for a NRA who does not have an ITIN is not prohibited by your policy you should not have a problem as long as you complete CIP. We use the passport number as the identifying number for CIP. If the NRA will be joint holder of a savings account you should have him/her complete a W8BEN but have the other owner (with ITIN) as the primary holder of the account for 1099 purposes. For ongoing monitoring purposes I suppose you would want to see if the NRA has any activity that would indicate work in the US (not easy).

Your comments reflect our current CIP policy and account openeing policies. I think we are in good shape, then. Thanks!

If they have been approved to work, they will have SSN. If they are going to be on someone's taxes (such as spouse or dependent child), they will need to obtain ITIN. Otherwise, no U.S. number is needed.

W-8BEN is used to document non-resident aliens; expires every 3 years unless person has U.S. TIN (SSN or ITIN).

W-9 is used to document resident aliens.

If they don't have a TIN or an ITIN we do not open the account. Simple.

ditto that

Do you find that helps you better manage RA/NRA issues? You still have different documentation methods (W-9 vs W-8BEN)and staff still should understand who should have SSN vs. ITIN.

The only thing I can think that you are avoiding is having to follow up on expired W-8BENs. Which is nice - no constant contacting clients to obtain new form and no WH needed.

What are the other advantages?