W-8 & W-9 Information
IRS W-8 and W-9 forms are no longer used solely for the purpose of reporting taxable income.
New Internal Revenue Service (IRS) guidelines regarding the Foreign Account Tax Compliance Act (FATCA) went into effect July 1, 2014.
- FATCA requires payors such as Vanderbilt University to:
- Have procedures in place to identify withholdable payments and categorize non-US payees.
- Have procedures in place to report and potentially apply withholding tax to avoid liability and exposure to potential penalties.
- To verify each payee’s FATCA status with the receipt of appropriate documentation (the correct W-9 or W-8 form)
The US Department of the Treasury's Office of Foreign Assets Control (OFAC) prohibits payments to any person or entity that has been added to any of our government's sanction lists.
Tax identification matching (TIN matching) is used to verify that W-9 information matches with the taxpayer's record on file with the IRS. Disbursement Services uses this process to minimize information reporting errors when filing our annual 1099 reporting with the IRS.
Vanderbilt University cannot meet the IRS’s FATCA requirements, OFAC requirements or TIN matching without acquiring the appropriate W-8BEN or W-9 form from each payee.
W-8BEN and W-9 forms are legal documents that are kept on file as proof we have exercised due diligence in our TIN matching efforts and in validating that we are not paying sanctioned payees.
Based on interpretation of the above IRS requirements:
- Vanderbilt University now requires the correct W-8BEN or W-9 for all payees who are not current students or employees.
- This includes all vendors/suppliers, guests and visitors.
- Currently, only the following exemptions apply:
- University payment card purchases from US entities
- Patient refunds
- Student refunds
- Employee and/or student reimbursements and miscellaneous payments (identification has already been verified)
- Registration refunds related to Vanderbilt sponsored camps, conferences, etc.
- Subject participants who complete an internal form including:
- Full name and social security number
- Statement of US or non-US citizenship