Filing of forms 1042-S and 1099: new filing solution with the IRS going live in 2027

With the retirement of the Filing Information Returns Electronically (FIRE) system by the end of 2026, Qualified Intermediaries (QIs) who have been filing US information returns (e.g., Forms 1042-S and Forms 1099) with the Internal Revenue Service (IRS) through FIRE will be generally required to use the new International Data Exchange System (IDES) starting in 2027. Affected QIs will not be able to access IDES until after registering for and receiving from the IRS a Foreign Filer Transmitter Control Code (TCC).

A New Solution to Pre-existing Blocking Points

When the transition from FIRE to the Information Returns Intake System (IRIS) was originally announced, the shift appeared to be unworkable for most QIs and other filers outside the US. Accessing and authenting in IRIS requires the filer to have at least one authorized user having a US Individual Taxpayer Identification Number (ITIN) or Social Security Number (SSN), which most QIs would not be able to obtain for their authorized users.

Based on feedback received from the QI community, the IRS has developed an alternative solution for non-US filers without authorized users having an ITIN or SSN.

In May of this year, the IRS announced its solution (see here). The Foreign Filer Transmitter Control Code (TCC) Registration System will allow QIs to submit information returns electronically through IDES instead of IRIS. On 19 August, the IRS made a specific call for action urging eligible non-US filers to complete their Foreign Filer TCC registration in advance of the 2027 filing season (see here).

What Needs to be Done

Affected QIs need to ensure that they are ready in 2027 to submit their information reporting for tax year 2026 through IDES. A QI will only be able to enrol in IDES after first registering for and receiving from the IRS their Foreign Filer TCC, which requires that it satisfy all the following preconditions:

1. Creating an account with Login.gov or ID.me (if not already created);
2. Obtaining a Foreign Filer ID;
3. Acquiring a TTC GIIN; and
4. Obtaining a TTC.

The full process and estimated wait times are shown in the below flow-chart provided by the IRS during its webinar hosted on 26 August:

The detailed process is described below.

1. First, the QI identifies its “authorized users,” which must include one “Responsible Officer” (RO) and up to five optional “point(s) of contact” (POC(s)). As a reminder, if the RO or any POC has an ITIN or SSN, then the filer should file its information returns via IRIS instead of IDES.
2. The RO or a POC must sign into their credential on Login.gov or ID.me from the Foreign Filer TCC Registration page. Individuals without an existing Login.gov or ID.me credential must first create one. To prevent delays later in the process, the IRS recommends ensuring early that a valid credential exists.
3. The RO or POC next creates a new Foreign Filer TCC account and will receive a Foreign Filer ID before registering to obtain a TCC GIIN.
4. To obtain a TTC GIIN, the following information must be provided:
   
   • The official name of the firm or organization;
   • Firm or organization’s mailing address;
   • Details for the RO; and
   • Details for additional POC(s) (optional).
   
   It can take one or two business days to be issued a TCC GIIN. The IRS will send an email notification to the RO once the TCC GIIN has been issued.
5. With a TCC GIIN, the RO or POC can request the TCC, which is required to enrol in IDES.
   
   
   • To request the TTC, it is necessary to provide the firm or organization’s QI-EIN.
   • The “Request TCC” option will not be available until after the TCC GIIN has been issued.
6. IDES enrolment also requires an Authorized Security Certificate from an approved Certificate Authority. If already in possession of a digital certificate meeting the IDES requirements (such as one used for FATCA), it may be possible to use it.
7. The IRS advises waiting to enrol in IDES until three to six weeks after issuance of the TCC. Once ready to enrol, the RO must complete the initial IDES enrolment and serves as the primary account contact.

When to Begin

The IRS has recently indicated that it plans to allow IDES users to submit test returns in October 2026. Any filer who intends to make use of the October testing window should enrol in IDES, by first registering for a Foreign Filer TCC, as soon as possible.

How to Avoid Common Mistakes or Delays

The following tips were shared by the IRS:

• To create or access the Foreign Filer TCC account, always begin from the irs.gov Foreign Filer TCC Registration page, not from the Login.gov or ID.me sites.
• When registering for the TCC GIIN, the applicant will need to have credentials for the appropriate Login.gov or ID.me account, using the same email address as the RO or POC.
• Ensure that the QI’s legal name and QI-EIN used in the Foreign Filer TCC registration match IRS records to avoid processing delays.
• Record the Foreign Filer ID as soon as it is issued because it is needed every time to access the account.
• Don’t confuse the Foreign Filer ID with the TCC.

Deloitte's view

QIs needing to use IDES in 2027 to file their Forms 1042-S and 1099 for calendar year 2026 should begin their Foreign Filer TCC Registration as soon as possible to obtain the necessary TCC to enroll in IDES. We are here to help in case any questions arise along the way.

Authors

• Bernhard Schopper – Partner, Tax & Legal
• Elena Bonsembiante  – Senior Manager, Tax & Legal
• William Holloway – Manager, Tax & Legal