It was recently suggested to us after an internal audit to request new W-9s every three years. Is there documentation that backs this up?


The IRS does not require a periodic re-solicitation of W-9s. You should obtain a new W-9 when you know of or have reason to suspect a change of name, tax ID or tax status of a vendor. But there is not any statutory requirement for regularly soliciting new W-9s (unlike W-8s). Neither are we suggesting that there is anything wrong with periodic re-solicitation, though you should weigh the work effort involved.

Note that with the FATCA changes, you do now want to obtain a W-9 from new vendors that are U.S. corporations, due to FATCA presumption rules. The actual requirement is to have “documentary evidence” that a corporation is a U.S. entity, and “documentary evidence” could be a W-9, but it could also be a copy of the company’s articles of incorporation—it does not have to be a W-9. But it probably will be easier to get a W-9 than other kinds of documentation. You do NOT have to solicit W-9s from your existing vendors that are corporations; it only applies from 1/1/2015 to new vendors.

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