Letters

IRS on Notice 2017-09 De Minimis Error Safe Harbor

Summary

SIFMA submits comments on the Internal Revenue Service’s (IRS) Notice 2017-09, which includes guidance to implement changes made by the Protecting Americans from Tax Hikes Act of 2015 (the “Path Act”) on the de minimis error safe harbor from information reporting penalties under Internal Revenue Code (the “Code”) sections 6721 and 6722 and the payee election to have the safe harbor not apply. SIFMA notes that the system framework needed to support all the data for the elections made pursuant to the proposed regulations would be an intensive undertaking for the industry, and would require more resources than maintaining the current state of issuing de minimis error corrections. We offer suggestions to prevent this from occurring. We also request guidance on elections for joint accounts.

See also:
De Minimis Error Safe Harbor to the I.R.C. §§ 6721 and 6722 Penalties

PDF

Submitted To

Internal Revenue Service (IRS)

Submitted By

SIFMA

Date

12

June

2017