Every organization that files Forms 1099 needs compliance procedures and training for the rules of “TIN compliance” and the correct handling of IRS B Notices and 972-CG proposed penalty notices. This presentation will show you how to implement effective TIN compliance in your organization.
- How to initially solicit taxpayer ID numbers (TINs), then use the free on-line IRS TIN Matching Program to validate Name-TIN combinations of the payees you plan to report on Forms 1099. By screening well in advance of 1099 filing, you will have time to solicit new information for “bad” TINs and achieve more accurate 1099 filing.
- Regulatory requirements your organization must implement if certain 1099-reportable payees fail to furnish their TIN.
- How to process IRS Notice CP2100 or CP2100A, the “B Notice” of missing and incorrect TINs, including internal research in your files, annotating the list, soliciting Forms W-9 or other required new documentation from payees, backup withholding federal income tax on time where required, and recordkeeping.
- Using your records of TIN solicitation and compliance with the CP2100 and backup withholding process to build a “reasonable cause” response to the IRS if your company receives a Notice 972-C proposing penalty assessments.
Learning objectives: Correctly conduct TIN solicitations, process IRS Notice CP2100 and respond to IRS Notice 972-CG.
Marianne Couch, JD - Principal, Cokala Tax Information Reporting Solutions, LLC
Marianne Couch, JD, is a Principal in the Cokala tax group and an experienced and well-known advisor on U.S. federal and state tax information reporting compliance. She is a frequent lecturer at major tax conferences and the author of The Master Guide to Form 1099 Compliance, The Master Guide to Form 1042-S Compliance and numerous published articles. Prior to co-founding Cokala in 2007, she was for many years the Research Director of the tax reporting specialty firm Balance Consulting, and chaired special training and advisory services provided to large organizations and academic and nonprofit institutions.
Marianne was an appointee for three years to the IRS Commissioner’s Information Reporting Program Advisory Committee (IRPAC), where she was Chair of the IRPAC Subcommittee on Small Business and Self-Employed (SBSE) tax issues.
Marianne formerly served as a Research Attorney for the Michigan Court of Appeals, and earlier as a litigator for a large Michigan law firm, where she represented individuals and large clients in many types of civil actions. She received her JD, cum laude, from the Michigan State University School of Law, and is a member of the State Bar of Michigan.
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