M E M O R A N D U M

March 14, 2011

TO: Distribution

FROM: Burt, Staples, Maner, LLP

RE:   Electronic Form W-8 Validation Takes Off           

Electronic validation has grown exponentially in the past two years and is becoming the popular tool for US withholding agents and qualified intermediaries (“WAs”) to obtain Forms W-8 and W-9 quickly and efficiently from clients and vendors without spending hours collecting, validating and revalidating paper documentation. Compliance Technologies International, LLP (“CTI”), a pioneer in the electronic validation field, is leading the way to compliance with its Digital W8TM and E-W8 applications.

This past year, CTI has obtained IRS approvals on behalf of its clients for an increasing number of Memorandums of Understanding (“MOU”) for electronic W8 systems. The MOU, among other advantages, provides WAs with audit protection for their systems and limits the scope of future IRS audits while the MOU is in effect. To date, CTI has designed and/or built electronic W8 solutions for more than 50 entities for whom CTI has negotiated MOUs with the IRS. This trend continues in 2011, with CTI helping dozens more clients seek and secure an MOU from the IRS.

CTI’s Electronic W8 Offerings

The majority of these MOUs have been issued for CTI’s Digital W8TM or E-W8 applications, showing CTI’s dominance in the electronic W8 validation market. The Digital W8TM and the E-W8 applications electronically automate the solicitation, renewal, and validation of Forms W-8 and W-9 and assist beneficial owners with the completion of Forms W-8 or W-9 online. The E-W8 application is ideal for financial institutions and online banking and brokerage firms that want to reduce the ongoing burdens and costs of paper solicitation and re-solicitation. Digital W8TM is the perfect choice for multi-national corporations (“MNC”) and financial institutions looking for the same benefits of the E-W8 application, which uses an on-line interview process to assist domestic and non-US vendors receiving payments for non-financial income such as personal services income, business profits, and/or royalties to complete forms properly.

Expanding on CTI’s existing form validation tools (MD3 and MD4), the E-W8 and Digital W8TM applications use similar validation engines for the validation of Forms W-8 and W-9. Additionally the E-W8 application integrates the document collection process into a client’s existing portal and account opening/maintenance process, while Digital W8TM is integrated into the MNC’s portal and vendor management process. Since the MOU process now is streamlined and requirements consistently established, more WAs seriously consider utilizing electronic W-8 tools. Additionally the IRS is hinting new Forms W-8s will be issued in advance of the effective date of the Foreign Tax Compliance Act, another incentive for WAs to improve their current validation processes.

To learn more about CTI and its electronic validation tools, visit our product section. If you have any questions, please feel free to contact us by phone at (202) 783-1553 or by email at cdaftary@bsmlegal.com.

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