For tax years 2022, 2023 and 2024, under Notice 2023-11, the United States (US) Internal Revenue Service (IRS) has announced that it will not require certain foreign financial institutions (FFIs) to furnish US tax identification numbers (TINs) for accounts preceding the effective dates of the Foreign Account Tax Compliance Act (FATCA) and associated Intergovernmental Agreements (IGAs).To qualify for this temporary relief, FFIs must meet certain requirements.To the extent the relief requirements are impractical given the number of US reportable accounts without TINs, some FFIs, including Luxembourg financial institutions (FIs), will need to decide whether to seek relief under the same...