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The qualified substitute gives you a statement, under penalties of perjury, that the certification is in the qualified substitute's possession. If a title or escrow company is not willing to act as a qualified substitute, then the seller will have to complete the AS Form.A Qualified Substitute is a person or entity as defined under FIRPTA that accepts a Seller's completed and signed Seller's Affidavit in the Buyer's stead. FIRPTA Withholding is NOT Required. Thus, was created the "Qualified Substitute" rule, which contemplated that the title company or attorney closing the transaction would serve in that capacity. Buyer, or authorized qualified substitute, must retain this Affidavit for not less than five (5) years. Seller Signature: Date: Print Name: Seller Signature:. How to Complete a FIRPTA form - Seller's affidavit of non-foreign status. Substitute. Since 2008, a transferor may provide a completed non- foreign certification to a.