Is the 2014 version of the W-9 still acceptable? I have vendors who are refusing to complete version 2014.


The current version of the W-9 is the December 2014 version; the prior version was August 2013. In answer to your questions, here are a couple of points. The W-9s on file for vendors with whom you have already been doing business are acceptable—you do not have to resolicit new W-9s from existing vendors.

However, new vendors should use either the current form (December 2014) or a substitute W-9 that comports with the December 2014 version, which has been updated to include FATCA status codes.

Note that for chapter 3 withholding/reporting, a W-9 is not required, except when a B-notice has been issued.  You must have a tax ID number, and the W-9 is the recommended documentation of the tax ID as well as of tax status for vendors. It is best practice to obtain a W-9 from your vendors (prior to first payment!). But there is not a law requiring them to provide it to you.

However, if the payment is subject to FATCA (e.g., interest payments), then new presumption rules mean that without documentation, you must presume a payee (including corporations) are foreign, and withhold 30% of the payment. Documentation in this case can be a W-9, though it can also be articles of incorporation, since what you are documenting is whether their status is U.S. or foreign; generally it’s probably easier to get a W-9 than other documentation.

We would want to understand why a vendor refuses to use the current version of the W-9—it is in their best interest to do so. Without proper documentation, FATCA-related payments are subject to withholding.

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