IRS TIN Matching Program grief from local HUD office

[Shawn H.]

I'm getting some grief from the local Housing Office due to their failure to understand complex real estate title holding strategies and the IRS TIN Matching program.

1) The Housing Office wants to know who the owner of a property is by supplying a copy of the deed.
2) They want to match the SSN/EIN of the owner for 1099 purposes using the IRS TIN matching service.

Easy, right? Well, not so easy if you are holding title in trust and the trustee is different from the beneficiary.

The "owner" is just holding title and they are not receiving the benefit of the property and obviously don't want a 1099 at the end of the year for gross rents on a property they do not enjoy the financial benefits of.

The "beneficiary" EIN number is a different entity altogether but is the person/entity that should be getting the 1099.

We supply the EIN of the beneficiary, the housing office does TIN matching against the "owner trustee", and it doesn't match. They throw it back at us.

And the housing office will withhold rent if they get too frustrated, so I have to fix this in a way that they will understand -- or just not rent to Section 8 tenants, which isn't a bad option either.

Anyone else run into this and how did you get through their thick skulls?

Thanks!