Not really a BSA question, but I wouldn't know where else to ask.
If we have a customer that fills out a W-8BEN and has a TIN but we did NOT file a 1042-S last year.... is the W-8BEN no expired or would we wait 3 years from the date the 1042-S wasn't filed? The instructions spell out how to handle the 3 year expiration, but not how to handle the ITIN/1042-S issue if that portion isn't met.