How to Evaluate Your Provider’s Electronic 1042 Filing Readiness

Kelly Conner
November 14, 2023

This blog was last updated on February 28, 2024

Changes announced: Click here for the most up to date Form 1042 information.

With the IRS changing the filing requirements for Form 1042 to be electronic, businesses must ensure that they are working with a provider that is properly prepared for those updates. Here are key things to keep in mind when evaluating your provider’s electronic 1042 filing readiness.

Verify your provider is an Approved IRS Modernized e-File Vendor

For a provider to be able to submit your organization’s 1042 information electronically, it must go through rigorous testing with the IRS to become approved as an IRS Modernized e-File (MeF) business provider. This approval process shows that the IRS has vetted the vendor’s people and systems to ensure they are providing compliant solutions and services. If the IRS has not provided a list of approved providers for the upcoming tax year, it is recommended to go with a vendor that has previously been approved. This shows that the vendor has an established track record, has experience navigating the approval process and has system outputs already built and previously tested to ensure compliance.

Align on electronic reporting requirements

Simply selecting any vendor could introduce your organization to unwanted penalties or audits downstream if they have different interpretations of the new 1042 electronic filing requirements. Below are some suggested topics to bring up with your future provider, or verify on their website, to make sure you are both aligned on how your filings will be processed:

  1. Confirm they are filing 1042 returns through the IRS MeF system
    Because the IRS and the Treasury buried this new filing requirement into TD 9972 it has been challenging for businesses and vendors to get on the same page regarding the electronic filing requirement. Ensure your vendor understands the 1042 filing return is to be filed electronically and that they have taken the proper steps to get registered with the IRS MeF System as an approved filer.
  2. Understand how they are handling Line 67’s Claim Credit
    If you are filing Line 67 on Form 1042, then it’s important to verify a couple items. First, you’ll want to understand if they will support Line 67 or the ability to upload 1042-S forms to your 1042 filing. If they can support this, it’s also important to understand if they support filing six-month extensions (Form 7004) and/or if they’ll honor the six-month extension when filing 1042 filing returns in the month of September instead of March.
  3. Confirm if they require and retain Form 8879, IRS E-File Signature Authorization
    If a vendor is reporting on your organization’s behalf, they need to get your consent to electronically sign and file on your company’s behalf. To do this, most organizations will capture that electronically within a product – or they will require your organization to provide a completed Form 8879 providing them access to file. Without either of these two authorizations in place, the provider should not be electronic filing on your company’s behalf.

Understand their end-to-end process

Understanding the end-to-end process is important so you are aligned on what to expect from the provider, but also to ensure you are getting the information you need to protect your organization from penalty or audit situations. With Form 1042 being a Tier 1 audit item for the IRS, it is considered an enforcement priority. As most audits go, if the IRS finds that you were non-compliant with your 1042 filing returns, they will continue to poke around your business to find additional areas of non-compliance on which they can assess hefty penalties. Some questions you can ask your provider to ensure your company is protected in the event of penalties or audits include:

  1. Will your provider give you submission receipts showing that your file has been uploaded to the IRS MeF system and an acknowledgement file with status record indicating accepted or rejected?
  2. Will your provider have access to a complete audit trail that documents when and where changes were made, who made them and what changed?
  3. If you need to make adjustments to your filing return, will the vendor support amendments?

Take Action

Still have questions about evaluating your provider’s 1042 e-filing readiness? Reach out to our team to learn more.

Sign up for Email Updates

Stay up to date with the latest tax and compliance updates that may impact your business.

Author

Kelly Conner

Kelly Conner is the Director, Product Marketing for Tax & Regulatory Reporting at Sovos. She has been with Sovos for 8 years and is responsible for directing a team that establishes the marketing strategy and direction for Sovos’ 1099, Affordable Care Act, Unclaimed Property, and Statutory Reporting solutions based on industry and client needs. Previously at Sovos, Kelly served as a customer service representative, where she serviced Sovos’ largest customers with unique tax reporting requirements. Kelly holds degrees in Marketing and Communication Studies from the University of Wisconsin-La Crosse.
Share this post

Hungary Supplemental Insurance Premium Tax
EMEA IPT
July 11, 2022
Extra Profit Tax: An Introduction to Supplemental IPT in Hungary

This blog was last updated on October 28, 2024 Update 7 October 2024 by Edit Buliczka Hungarian Tax Office Updates IPT Declaration Form for 2023 The procedure necessary to correct an underdeclared premium figure in Hungary can be complicated. The complexity of a correction for return form 2320 has become even more challenging. Following a […]

sales tax vs. use taxes
North America Sales & Use Tax
November 8, 2024
Demystifying Tax Types: Sales Tax vs. Seller’s Use Tax vs. Consumer’s Use Tax

This blog was last updated on November 8, 2024 One of the core concepts in sales tax compliance is also one of the most frequently misunderstood: the differences between sales tax and use tax. These tax types may look similar on the surface, but knowing the differences is essential for staying compliant and avoiding costly […]

2025 bond project
North America Tax Information Reporting
November 4, 2024
The Insurer’s Guide to the 2025 Bond Project

This blog was last updated on November 4, 2024 The regulatory landscape for insurance companies is undergoing significant changes with the Principles-Based Bond Project which is set to take effect on January 1, 2025. These changes, driven by the National Association of Insurance Commissioners (NAIC), will impact how insurance companies classify and value bond investments, […]

E-Invoicing Compliance EMEA VAT & Fiscal Reporting
November 1, 2024
VAT in the Digital Age Approved in ECOFIN

This blog was last updated on November 7, 2024 The long-awaited VAT in the Digital Age (ViDA) proposal has been approved by Member States’ Economic and Finance Ministers. On 5 November 2024, during the Economic and Financial Affairs Council (ECOFIN) meeting, Member States unanimously agreed on adopting the ViDA package. This decision marks a major […]

what is peppol
E-Invoicing Compliance North America
October 29, 2024
What it is PEPPOL?

This blog was last updated on October 29, 2024 Peppol E-invoicing explained: What it is and how it works The global adoption of electronic invoicing is accelerating. Governments worldwide are pushing to adopt e-invoicing to digitally transform their national systems and, often, to close the VAT gap. While many countries have introduced their own e-invoicing […]

remote sellers sales tax
North America Sales & Use Tax
October 28, 2024
Will Congress Act to Simplify Remote Seller Sales Tax Collection

This blog was last updated on November 5, 2024 When the United States Supreme Court ruled in 2018, that South Dakota’s law imposing sales tax collection requirements on sellers without in-state physical presence was constitutional, it did not grant states free reign. States are still responsible for ensuring that their sales tax requirements are manageable, […]