Who is Impacted
Any organizations making payments subject to U.S. federal tax withholding and information reporting or any Automatic Exchange of Information (AEoI) filing requirements under the Foreign Account Tax Compliance Act (FATCA) or the Common Reporting Standard (CRS) will be interested in a few suggestions of tasks to consider while we wait for our new normal due to the COVID-19 virus.
What Changed due to Covid-19
Ah, so much has changed in the last two months, and many of us have found ourselves at home with more time on our hands – although, sometimes it can seem like even less! Deadlines keep getting pushed, remote working is the new normal, limited access may be impacting you, and paper filing restrictions are becoming looser, allowing for more electronic signatures and submissions. With this in mind, we have gathered a list of suggestions that our fellow industry folk can consider while we work from home and still have access to many of our files at work.
Identify Areas for Improved Remote Access. Have you found that certain tasks, access to certain files or programs are not working as well as you would like while you try to do your job from home? Keep a list of these items and make sure you get connected internally with those who are looking at technology and organization wide improvements to make sure you communicate your improvement wish list! Working from home may become more acceptable and part of the new normal. It will certainly be the new normal for any future pandemics. Having access to all the data, files and programs needed to do your job is critical. And don’t forget to review your policies and procedure manuals to make sure you have incorporated all the changes for these emergency situations that could require new workflows. It may be a good time to update these manuals for changes that have taken place over the last months to make sure that your procedures are in line with your actual processes.
Reconcile your files. Now is a great time to take a look at all of your information reporting and withholding files. Send through a few queries and take a look at what data you have on files. Are there any gaps? Are you missing any taxpayer identifying numbers, whether they are U.S. or non-U.S.? Are your withholding rates up to date? How were your reporting numbers for the last cycle? Were your amounts reported and control totals in balance? Check in with all of your administrative and management reports to see where you can improve your data. If you are unsure of how to run these reports, ask your internet technology folks or even schedule a quick meeting with your vendor for support. If you identify areas where you are lacking access to data, make sure you keep a list and document resolution! Reconciling your files and cleaning up missing data or documenting resolutions to issues is a great way to make sure your organization is audit ready.
Resolicit. Are there any expired withholding certificates on file? Consider running an administrative report to understand whether you have expired forms, forms that have had a change in circumstances are need updating, or where you are missing forms in general. Do you collect withholding certificates electronically? Considering many regulatory rules have been relaxed to allow for electronic submissions and signatures, now might be a good time to have a look at pushing these forms to electronic versions. Consult vendors to help answer questions and support your needs, which leads us to our next suggestion!
Consider more electronic capabilities. Are there processes that you could automate at this time? Thinking about your entire process flow, could you move any part of it from a manual process to an electronic or automated process? Now that we have learned to do so many things remotely, are there other ways you could continue automating? Understanding that there are certain processes where you cannot substitute human intellectual though, where are there repeatable processes that you can push to automation? In addition to identifying new processes to automate, it is also a good time to revisit old processes and ensure they are working in this decentralized working environment. Are all communications making it to those in need? Does your internal communication system to share information work or does it need to be tweaked for new technology?
Request IRS Transcripts. Request IRS transcripts to reconcile amounts deposited to amounts withheld and confirm what that you will be reporting. This will help identify what you should expect to report and to help reconcile whether the withholding you have on your records equals the federal deposits.
Outstanding IRS Notices. Do you have a process for managing and responding to IRS Notices? It might make sense to have a look at what you have on file and to determine whether there are any outstanding at this time. Are there any Notices that your organization received that might require you to revisit certain processes, so that you do not receive the same Notice next year?
Review vendor contracts for updates. In your spare time, it might be a good idea to dust off your vendor contracts to see what they cover. Have they been updated? Are your applications and solutions up to date? Be sure you have the latest release from your vendor and that there is a plan for implementing all updates for 2020 reporting.
Training. Are you behind in your training, your preferred conferences cancelled or delayed, or looking for new areas to learn? Now may be a good time to look at online training, getting current in your CPE required hours or learn new areas that will help you adapt to these changing times while remaining compliant.
Stay updated! For all other updates and additional information please visit the following links:
The Department of Treasury:
The U.S. Government:
https://www.usa.gov/coronavirus (In English)
https://www.usa.gov/espanol/coronavirus (In Spanish)
Update on OECD Tax Work:
Center for Disease Control (CDC):
How to Implement
As a way to implement and summarize this article, consider the following:
- Identify the files and programs you are lacking access to while working from home and connect with those in your organization working on technology and remote access for the future.
- Be aware of filing deadlines and dates. Maintain and update a tax calendar on hand for all departments impacted by U.S. federal tax withholding and reporting.
- Perform your reconciliation processes now and confirm that correct information is feeding your reporting systems and identify any issues and resolutions sooner than later.
- Request IRS transcripts!
- Consider automating as many processes as possible.
- Check in with vendors. Ask what will be updated for the coming year and if there are any useful administrative or managerial reports you should be using.
We have now officially launched ComplyPro, a new subscription-based platform that should help ease the difficulties of day-to-day Tax Information Reporting & Withholding requirements.