April 28, 1994
TO: OPERATIONS MEMBERS NO. 14-94
TAX MEMBERS NO. 17-94
TRANSFER AGENT ADVISORY COMMITTEE NO. 17-94
RE: REVISIONS TO FORM W-9 AND INSTRUCTIONS
__________________________________________________________
The Internal Revenue Service has released the attached
revised Form W-9, Request for Taxpayer Identification Number and
Certification and instructions for both the Form and payors
requesting the Form. The Form has not been changed materially.
The Instructions for the Requester of Form W-9, however, have
been revised to include a new limitation on the use of substitute
Form W-9s. Specifically, the instructions now provide that a
payor "may not use a substitute form to require the payee, by
signing, to agree to provisions unrelated to TIN certification."
The Institute has already expressed concern regarding this
change to the IRS. The Institute is preparing a further
submission on this matter. Please contact the undersigned with
any comments you have regarding the revised rules for substitute
Forms W-9.
We will keep you informed of further developments.
Peter J. Cinquegrani
Assistant Counsel-Tax
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