handle IRS "b notice" / cp2100 (backup withholding for TIN mismatch)?

[RandomEtc]

Any plans to handle the "sad path" of 1099 filing, cp2100(a) (aka B notice), when TINs and names on 1099s you generate don't match IRS records?

https://www.irs.gov/pub/irs-pdf/p1281.pdf

[adamdecaf]

Great question Tom! I have a few questions / topics from that:

• It looks like we would need to store a reference that a CP2100 (and later a CP2100A) notice has been received for a specific document. In WIP: document storage  #50 we're starting to add the concept of a document_id this could be associated to.
• The corrected file would need to be created and submitted. We're going to support submitting files, so corrected files will follow suit.
• Our library doesn't support W9's right now, which is a requirement of this.
• The ledgering support for B notices seems out of scope for this project.
• We need to handle parsing the B Notices?

Does this sound correct so far?

[RandomEtc]

I'm no tax expert but that sounds about right.

If I understand the PDF I linked, B notices might be supplied on paper (<25 errors) but usually end up being delivered by CD/DVD! I hope by the time you're adding this that they support SFTP ;)

For W9, I leave it to y'all to consider if it lives in irs, watchman or customers, or someplace else. There's some fairly clear guidance on required language and what to collect for a "substitute" here: https://www.irs.gov/instructions/iw9#idm140098828624048

If I understand your note, I think the ledgering requirements for B notices would need to be supported wherever you're paying interest or wherever you'd otherwise have to set aside withheld funds - agree that's out of scope for the irs project as you've positioned it so far. Probably accounts in moov land?

[adamdecaf]

Ouch. CD/DVD would require a human to read those off and likely manually find the linked records.

The ledgering requirement would be outside moov-io/irs for sure, but part of a larger Moov service.