Who Can Participate and What Name/TIN Combinations Can Be Submitted?
The supporting legal structure is synthesized in IRS Rev Procedure 2003-9 published earlier this year. (The Rev. Proc. mentions IRS Publication 2108, but the author has been unable to locate a copy on the IRS web site.) Other resources are an apparently unofficial “Frequently Asked Questions” worksheet as well a Power Point slide presentation, both developed by IRS personnel. In essence, TM users must be “payors” filing information returns for income that is subject to backup withholding. For example, a Form 1099 INT used to report interest paid on bank deposits qualifies. However, a Form 1098, used to report interest received on real estate mortgages, does not. Unless a payor files information returns involving backup withholding, it cannot use the TM program. Nevertheless, banks, thrifts and credit unions will obviously qualify to use the service. However, the TM program’s scope is further narrowed by the fact that: “Participants in the Program musttransmit only name/TIN combinations
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