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Procurement Mgr decision scenario

I am looking for some thoughts on the following purchasing scenario. Two POs were submitted for parts and services at the same location, same vendor, same type service, same date, same requester, same scope and same account to charge. One PO was for $9500 and the other for $9800. Your agency's limit to purchase before being required to get 3 quotes is $10,000. Only one quote was submitted for the PO. Additionally, the POs were requested 3 days after the PO cutoff of June 5. The quotes were dated March 31. Please select one of the following scenarios or provide your own. A) Would you ignore and process as both came in under the procurement limit. B) Would you flag both POs as questionable since it looks like they could have been submitted by splitting a project in such a way as to avoid getting more quotes and come in just under the limit. Then have a conversation with the requester and/or their boss. C) Would you deny both without further question or debate. D) Would you deem these to be an "emergency purchase" even though the date of the quote was written 45 days ago. or, E) None of the above. How would you handle this in your agency?

Thanks for your input,
David Griffin
The Public Building Authority

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Handling Foreign Account Tax Compliance Act (FATCA) Issues

We have been trying to find a definitive statement from the IRS as to whether we must have W-9 forms version 12-2014 for all our Vendors & Section 8 Landlords.  The new version has information pertaining to FATCA. FATCA is short for Foreign Account Tax Compliance Act which became law in March 2010. Because of this law certain forms for the IRS have been updated to capture information to help in enforcing the new law.  Version 12-2014 of form W-9 is one of these forms and one which we need to be aware of and address for KCDC.

According to the IRS;

  • FATCA targets tax non-compliance by U.S. Taxpayers with foreign accounts. 
  • FATCA focuses on reporting by U.S. Taxpayers about certain foreign financial accounts and offshore assets.
  • By foreign financial institutions about financial accounts held by U.S. taxpayers or foreign entities in which U.S. taxpayers hold a substantial ownership interest
  • The objective of FATCA is the reporting of foreign financial assets; withholding is the cost of not reporting.

We doubt whether any of our vendors have interest in foreign financial accounts or offshore assets, but, we are not sure who our landlords are.  We are not required, according to Price Water House Coopers Accounting firm, “to verify the person’s claimed FATCA exemption.  The FATCA regulations simply require the financial institution to collect a name, TIN, date, and signature.  Financial institutions can accept an entity’s claimed exemption status unless the financial institution knows or has reason to know that the information provided is incorrect.”

We have not been able to find a source, including the IRS which says we must contact everyone and get updated 1099 information.  But  the new version has been requested of KCDC several times and each time we have been asked to submit the 12-2014 version W-9 and told in email the new version would be the only one accepted.

How are other governments handling this requirement?

Thanks in advance

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