Are there any new rules with the new W-9? Do we have to have our vendors complete the new one from December 2014?


The IRS prefers you use the most current W-9 form available, which would be the revision issued in December 2014, according to IRS Information Reporting Specialist Miss Tennett (#10013007512).

However, if you have an older W-9 on file from a vendor, and none of that vendor's information has changed, you are not required to obtain an updated one. You will be required to get one if you receive a notice from the IRS that the vendor's current information does not match the information on the W-9 form you have.

The other significant change is that you should obtain a W-9 from any corporations that are new vendors. Because of FATCA regulations, there is a new presumption rule: you must presume an entity is foreign unless you have documentary evidence that they are U.S., and this applies to corporations, even though payments to U.S. corporations are still not reportable. This applies only to NEW vendors. You do not have to go back and solicit a W-9 for pre-existing corporate vendors—they are grandfathered. But obtain a W-9 from U.S. corps. (There is not a requirement to obtain a W-9 per se; for documentary evidence you could obtain articles of incorporation instead, but probably it’s easier to obtain a W-9.)

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