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You bet. If you go to the I.R.S. website and read a few paragraphs of form 8288, the language is unambiguous. It has a reasonable basis for a greedy government entity. If income tax is owed by a foreign national who doesn't have a taxpayer ID number, the I.R.S. can not collect it from them. So the regulations were changed to put the U.S. taxpayer on the hook. The first responder to this post questioned this situation between private individuals. I don't see anything in the I.R.S. rules that makes any distinction between individuals and time share companies. The I.R.S. wants the money ASAP. I was totally blindsided by this. One might think that a stellar timeshare broker would alert any potential buyers to this fact...