1099 compliance · TIN · SSN · ITIN · EIN · Name control · Form W-9 · Form W-8 · Solicitation · TIN Matching Program · CP2100 / CP2100A · B-Notice · Backup withholding · Form 945 · Letter 147C · CP 575 · Notice 972CG · IRC 6721 / 6722 · Reasonable cause · C-Notice · SDN list · SAM.gov exclusions · LEIE · IRIS · E-file threshold
1099 compliance
The everyday name for the whole process this site covers: collecting W-9s, verifying TINs, filing accurate information returns, and handling the notices that follow. Vendors call it TIN compliance; tax departments call it information-reporting compliance. Same work.
TIN (taxpayer identification number)
The nine-digit number the IRS uses to identify a taxpayer on an information return: a Social Security number, an ITIN or an EIN. The IRS matches the TIN together with the payee's name, so a real number with the wrong name still fails.
SSN (Social Security number)
The TIN for individuals, issued by the Social Security Administration. On a W-9, an SSN must be paired with the individual's own name on line 1, even if the individual operates a business.
ITIN (Individual Taxpayer Identification Number)
A nine-digit TIN beginning with 9, issued by the IRS to individuals who need a U.S. tax number but aren't eligible for an SSN. Treated like an SSN for W-9 and matching purposes.
EIN (Employer Identification Number)
The TIN for businesses, trusts, estates and other entities, issued by the IRS. It matches only against the legal name the IRS assigned it to, shown on the CP 575 notice or a Letter 147C.
Name control
The four characters the IRS derives from a payee's name to perform the match. It is why minor punctuation differences usually still match and a different entity name never does.
Form W-9
The form a U.S. payee uses to give a payer its name, TIN and tax classification, with a certification under penalties of perjury. The payer keeps it; it is not sent to the IRS.
Form W-8 (W-8BEN, W-8BEN-E)
The equivalent of a W-9 for foreign payees. A foreign payee is generally outside 1099 reporting and backup withholding and instead falls under chapter 3 withholding and Form 1042-S.
Solicitation
A request to a payee to furnish a correct TIN. Treas. Reg. 301.6724-1 sets a schedule (initial, first annual, second annual) that a payer must follow for a missing-TIN penalty to be waived for reasonable cause.
TIN Matching Program
The free IRS e-Services program that tells an enrolled payer whether a name/TIN pair matches IRS records, returning a code from 0 to 8. Interactive requests take 25 pairs; bulk files up to 100,000 with results in 24 hours.
CP2100 / CP2100A
The notice the IRS sends a payer listing the information returns whose name/TIN pairs didn't match (or had no TIN). CP2100A is the version for fewer than 50 errors. It starts the B-Notice clock.
B-Notice
The letter a payer must send a payee within 15 business days of a CP2100, asking for a corrected TIN. A First B-Notice encloses a W-9; a Second B-Notice (same account within three years) requires an SSA card copy or Letter 147C instead.
Backup withholding
The 24% a payer must withhold from reportable payments when a payee's TIN is missing, IRS-notified as incorrect, or otherwise flagged. It is deposited with the IRS, reported on Form 945, and credited to the payee on their return.
Form 945
The annual return for federal income tax withheld from nonpayroll payments, including backup withholding. Due January 31 (February 10 if all deposits were timely).
Letter 147C
An IRS letter confirming the legal name and EIN on file for a business, requested by calling the Business & Specialty Tax Line. It is what a payee provides in response to a Second B-Notice when the TIN is an EIN.
CP 575
The IRS notice issued when an EIN is assigned, showing the exact legal name tied to the number. The name on line 1 of a W-9 should match it.
Notice 972CG
The IRS's proposed penalty notice under IRC 6721 for information returns filed late, incorrectly, or with missing or incorrect TINs. The payer has 45 days to pay, agree in part, or request a waiver for reasonable cause.
IRC 6721 / 6722
Section 6721 penalizes a return filed with the IRS that is late or incorrect; section 6722 penalizes the corresponding statement furnished to the payee. The same per-return amounts apply to each, so one wrong TIN is usually two penalties.
Reasonable cause
The standard under IRC 6724 for waiving an information-return penalty: the failure was due to events beyond the filer's control (for TINs, the payee's failure to give a correct one) and the filer acted in a responsible manner, which for TINs means making the required solicitations.
C-Notice
An IRS notice telling a payer to begin backup withholding on interest and dividends because the payee under-reported that income. Only the IRS can lift it.
SDN list
OFAC's list of Specially Designated Nationals and Blocked Persons. U.S. persons may not pay or otherwise deal with anyone on it, and property must be blocked and reported within 10 business days.
SAM.gov exclusions
The federal government's list of parties excluded from federal contracts, grants and subcontracts, maintained by GSA. Anyone paying with federal funds screens against it.
LEIE
The HHS Office of Inspector General's List of Excluded Individuals/Entities. Federal healthcare programs will not pay for items or services furnished by an excluded party, so healthcare organizations screen vendors and staff against it.
IRIS
The IRS Information Returns Intake System, the free online portal for e-filing 1099-series returns, which the IRS is positioning to replace the older FIRE system.
E-file threshold
Since returns due in 2024, a filer with 10 or more information returns of any type in aggregate must file them electronically.