Caution:

When a flow-through entity is listed as a participant within the participants list, secure a listing of the persons within that flow-through entity that the applicant is requesting certification and verify their filing requirement.

Authorizations (Form 8821 or like form) from each participant for which certification is requested. The authorizations must authorize the 3rd party requestor to receive their tax information.

An authorization from the trust, when the requestor is other than a trustee in the trust.

The filing of the CTF's required return.

The filing of the required tax return of each CTF participant for which certification is requested.

A determination letter or proof that the participant is not required to file, when applicable.

An IRS Determination Letter or Revenue Ruling letter used as proof of exemption from taxation and filing, and a penalties of perjury statement, specifically stating that the organization was organized in the U.S. and carries out its exempt function primarily in the U.S.

Common trust funds, as defined in IRC 584, that apply for certifications for Switzerland with respect to dividends paid by a Swiss Corporation must also have the following attached to their Form 8802:

A list of each participant that is a trust forming part of a plan described in IRC 401(a), IRC 403(b), or IRC 457(b) or is a trust that is described in IRC 401(a), or IRC 403(b), for which certification is requested.

A statement that each participant listed on the attached list is a trust forming part of a plan that is described in IRC 401(a), IRC 403(b), or IRC 457(b), or is a trust forming part of a plan described in IRC 401(a), or IRC 403(b).

When none of the participants filed their required tax return, extension, or have a determination letter, reject the CTF application.

If any of the participants in the CTF failed to file, failed to provide authorization, filed as a non-resident, or filed a tax return claiming a foreign tax home (Form 2555 filed, see exception), issue the certification with a list of the participants/owners that are considered U.S. residents.