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IRS Finalizes Form W-9 (Rev. March 2024)!

The Internal Revenue Service (IRS) has issued the latest revision of the Form W-9 (Rev. March 2024). The latest form revision includes two notable changes:

  • Language was added to Line 3a to clarify how disregarded entities should complete the Form W-9: “Note: Check the “LLC” box above and, in the entry space, enter the appropriate code (C, S, or P) for the tax classification of the LLC, unless it is a disregarded entity. A disregarded entity should instead check the appropriate box for the tax classification of its owner.”
  • Line 3b, which appears identical to the draft version, has been incorporated into the final form. This requires flow-through entities to indicate if they have direct or indirect foreign partners, owners, or beneficiaries in order to satisfy any applicable reporting requirements.

You can access the most recent PDF version of the Form W-9 using the following link: Form W-9 (Rev. March 2024). You can also access the latest Instructions for the Requester of Form W-9 (Rev. March 2024)

What is Form W-9?

Form W-9 is a tax form used by U.S. persons, including U.S. citizens, U.S. organizations and resident aliens (unlike the Forms W-8, which are used by non-U.S. persons). It is officially titled “Request for Taxpayer Identification Number and Certification” and the purpose of the Form W-9 is for U.S. persons to certify their taxpayer identification number (TIN) and to identify their backup withholding status and any applicable reporting exemptions.

The information provided on a Form W-9 includes the name of the individual or entity, address, federal tax classification, exempt payee codes, if applicable, and TIN, which is usually a Social Security Number (SSN) or Individual Taxpayer Identification Number (ITIN) for individuals or an Employer Identification Number (EIN) for entities. By completing and submitting a Form W-9, the payee certifies that the TIN provided is correct and that they are not subject to backup withholding. Note: TIN checking is still important!

Understanding the Sunset Period

A “sunset period” typically signifies a phase-out or discontinuation period for older versions of tax forms or specific tax provisions. When the IRS releases a new form version or amends tax laws, a transitional period is often provided, unless otherwise noted, during which taxpayers can continue using the old form or adhering to the previous regulations before fully transitioning to the new requirements. Awareness of sunset periods is crucial to ensure compliance with the latest tax regulations.

For the Form W-9, the IRS is silent on whether the sunset period applies. Generally, the sunset period would apply similar to that of the Forms W-8, where it is outright stated that you may accept the prior version of the tax form until the later of 6 months after the revision date that is shown on the form or the end of the calendar year that the updated form is issued, unless the IRS specifically issues guidance that would affect the period for accepting the prior form version. The sunset period allows for time to transition, especially for technology companies, where getting new form revisions available can take time. If the changes made to the form are significant to your organization, then as a best practice it would be advantageous to incorporate the new revision as soon as possible. The March 2024 Form W-9 revision is available on the IRS website, so you can expect to receive it from your payees effective immediately regardless of any applicable sunset period.

Explore More about Form W-9

Interested in delving deeper into Form W-9? Check out our related articles:

IRS Finalizes Form W-9 Rev. March 2024 Thumb
IRS Finalizes Form W-9 Rev. March 2024

Comply Exchange offers tax software solutions for seamless collection and validation of IRS Forms W-9, W-8, and self-certifications. To discover how our services can benefit your business, schedule a demo today!

This document contains general information only and is not a substitute for accounting, tax, or any other professional advice or services. The information provided is considered accurate at the time of publishing and will not be updated with new regulation requirements.

Comply Connect – March 2024 – Issue 9

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