Refund Fraud Mitigation: Views from the Payroll Service Industry. National Payroll Reporting Consortium August 13, 2014
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1 Refund Fraud Mitigation: Views from the Payroll Service Industry National Payroll Reporting Consortium August 13, 2014
2 Proposed tax system modernization to accelerate W-2 and 1099 Reporting Information returns should be available to tax authorities during the income tax season Individuals filing income tax returns could fix problems at the time of filing No longer an active project as defined
3 Deadline for electronically filed W-2 data is March 31 February 28th in paper format States are far ahead of IRS in terms of electronic filing thresholds Only about 1% are required to file electronically Threshold set in 1982 when you needed a mainframe to file magnetically
4 Could employers electronically file W-2s and 1099s by January 31? Cash wages are generally known as of Dec. 31 But W-2s include up to 50 different elements of taxable compensation - many administered by third parties Third-party disability and sick pay is not required to be provided to employers until January 15th. Stock transactions, dependent care assistance, nonaccountable plan expense reimbursements, the value of company travel, personal use of a vehicle
5 NPRC is strictly policy-neutral on issues affecting employer reporting obligations. NPRC provides impartial feasibility analyses on proposals involving employment taxes Ernst & Young studied the feasibility of accelerating W-2 reporting deadlines Available at NPRC testimony at
6 Earlier deadlines: Shift deadlines for submitting W-2 and 1099 data from March 31 to January 31 or February 15. More frequent reporting: Require quarterly reporting of W-2 data, as some states already do. Increase electronic filing: Require electronic reporting from most employers. Shift the Income Tax filing season Delay refunds pending verification
7 Ernst & Young study: W-2Cs and amendments may multiply as much as eightfold Employers need time to gather the many elements of non-cash taxable compensation The time period between providing the W-2 to the employee and filing deadline helps employers file correct W-2s
8 IRS generally doesn t start information return matching until well into the tax season Workload implications: Would it help to match returns with whatever employer W-2 reports are filed as of the 1040 return filing date? E.g., as of mid-to late February? The W-2/1099 database would be incomplete; but May permit affirmative validation of a significant percentage of returns Do states routinely match returns to W-2 filings? Many state deadlines are earlier
9 Matching could eliminate most false refund claims E.g., fabricated employee-copy W-2s But sophisticated fraud rings may learn to file apparently valid & matching employer W-2s Authentication Codes? Authentication via CRAs and Public Data? For returns that score as potentially false Revenue agencies will likely need to take several actions - - no single solution.
10 Pilot project to generate an authentication code on Forms W-2 Would be entered/imported on the return to establish the W-2 as valid Known payroll firm Wages, withholding are unaltered May not help state tax authorities
11 Issues/limitations Code length to prevent reverse engineering E.g., 1A70C-F0DD8-6B2AC-E49F6 May be error-prone for data entry Key administration Not all W-2 issuers would get a key How to detect when a key is compromised
12 ELECTRONICALLY PREPARED PAPER RETURNS TO INCLUDE SCANNABLE CODE. TRUNCATED SOCIAL SECURITY NUMBERS ON FORM W-2. Truncated SSNs would states follow suit? State-copy W-2s are generally in the same envelope Do employees get anything else to verify their SSN? ACCESS TO THE NATIONAL DIRECTORY OF NEW HIRES FOR TAX ADMINISTRATION PURPOSES. INCREASE ELECTRONIC FILING OF RETURNS. Lower W-2 e-file threshold from 250 to 20 after 2016
13 RETURNS RELATING TO EMPLOYEE WAGE INFORMATION. shall be filed on or before February 15 STUDY REGARDING ADMINISTRATIVE IMPLEMENTATION. (1) a recommendation of whether the due dates for filing Forms W-2... should be accelerated to January 31
14 What is the experience of states with quarterly reporting? (CA, ME, MA, NY ) Has earlier reporting been effective? Don t try this at home Employer sequence number assignments Requirement to file W-2s before distributing to employees Print employer e-file acknowledgment on employee W-2s Both are used in Puerto Rico
15 Pete Isberg National Payroll Reporting Consortium, Inc
Things To Do Today: Fix Refund Fraud Problem. Views from the Payroll Service Industry. National Payroll Reporting Consortium August 5, 2015
Things To Do Today: Fix Refund Fraud Problem Views from the Payroll Service Industry National Payroll Reporting Consortium August 5, 2015 A trade association of the largest 12 payroll service providers
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