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Washington Alert – IRPAC report on TINs; e-file Providers must answer the annual self-certification questions; U.S. & San Marino sign IGA; revised Publication 4557, Safeguarding Taxpayer Data

Issues revolving around taxpayer identification numbers (TINs) are addressed in several recommendations appearing in the annual report of the Information Reporting Program Advisory Committee (IRPAC). (IR 2015-121) As stated in its report, the purpose of IRPAC “is to identify, and make specific recommendations for, areas of the information reporting program which can be improved by some change in operations, clarification of policy or communication with the public”. In its latest report, IRPAC called for penalty relief for name-TIN mismatches in cases where filers under current rules are not permitted to access the IRS TIN Matching Program. The panel also requested a new checkbox on Forms W-9 (Request for Taxpayer Identification Number and Certification) and W-4P (Withholding Certificate for Pension or Annuity Payments) to authorize information return filers to validate the payee’s name-TIN combination through the IRS TIN Matching Program. Additional IRPAC recommendations addressed the following topics: instructions for Form W-9; the reasonable cause penalty abatement process; the Foreign Account Tax Compliance Act (FATCA); the Affordable Care Act; cost basis and Form 1099-K (Payment Card and Third Party Network Transaction) reporting; the electronic transmittal of employer-withheld IRS tax levy proceeds; business taxpayer identity theft; and the treatment of negative interest for U.S. tax information. The number of reportable taxpayers and reportable transactions is steadily increasing – 2.29 billion information and withholding documents, including transmittals, are projected to be filed for 2015 and 2.32 billion for 2016. The complete IRPAC report is available at

IRS on Nov. 4 issued a reminder that, as of Oct. 1, e-file Providers must answer the annual self-certification questions to ensure they comply with Publication 1345 (Handbook for Authorized IRS e-file Providers of Individual Income Tax Returns) e-file security, privacy and business standards. (QuickAlerts for Tax Professionals) “If you are an Authorized IRS e-file Provider who owns or operates a website(s) that collects, transmits, stores or processes taxpayer information, IRS requires you to register the URL(s) for your website on your e-file Application”, the agency said. The annual certification process includes the registration of these websites, IRS stressed.

The U.S. and San Marino on Oct. 28 signed an intergovernmental agreement for cooperation to facilitate FATCA implementation. The agreement can be accessed at

IRS announced on Oct. 28 that revised Publication 4557, Safeguarding Taxpayer Data, A Guide for Your Business, is now in a PDF version that can be downloaded from the agency website. (QuickAlerts for Tax Professionals) The publication provides details on federal and state information security laws and regulations, as well as industry standards and best practices. “The document assists tax professionals in understanding their requirement to protect the privacy and confidentiality of taxpayer data and provides guidance to implement the necessary security controls within their business to satisfy these requirements”, IRS said. To download the publication, go to

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Meet Paul Raymond

Meet Paul Raymond

Mr. Raymond is a sought after speaker in tax controversy law by many attorney, accountant, and business groups and at the request of the Internal Revenue Service, has presented programs at the IRS Nationwide Tax Forum, attended by tax professionals throughout the United States.

Additionally, he continues to be an active member in the Section of Taxation, American Bar Association, where he was the Past Chair of the Employment Taxes Committee.

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Member CA Bar Member Orange County Bar US Tax Court Attorney