We are in the process of cleaning up our account information. I know that you must certify the TIN of the primary on an account. Do you have to certify TINs for joint owners? Or can we simply update our records without a W-9?

This question came up at an IRS Compliance seminar I recently attended. The certification is needed only for the primary account holder (the one that the 1099 will be filed for).

As you know, under the CIP proposal, Treasury plans to repeal current 31 CFR 103.34(a)(4). It provides that IRS rules determine whose number shall be obtained in the case of multiple account holders.

I am not aware of an IRS proposal to modify the TIN Certification rules, but it will be interesting to watch and see what, if anything, IRS does after the new CIP regulations are in place given that they will require us to obtain and retain a TIN from each U.S. person or non-U.S. person who has a TIN.