IRS Confirms Publication 1220 Error Related to Combined Federal/State Reporting System

Paul Ogawa
January 12, 2023

The IRS recently confirmed a printed error in their most recent release of Publication 1220, which contains guidance and electronic reporting specifications for 1099 forms and other information returns. In the December 2022 release of Publication 1220, the IRS published a table of state codes for the Combined Federal/State Reporting (CF/SF) system which included newly added codes for Washington D.C. and Pennsylvania. This update indicated that both jurisdictions now accepted returns through the CF/SF system. Neither jurisdiction confirmed this filing direction was accurate and maintained that direct state reporting of information returns is the only compliant filing process.

Sovos has since confirmed with the IRS via email that the CF/SF printed guidance in the December 2022 release is incorrect. Neither Washington D.C. nor Pennsylvania participate in, or accept records from, the CF/SF Reporting system. An updated Publication 1220 which removes the applicable codes from the CF/SF table is set to be released in the coming weeks.

To view Publication 1220 and the forthcoming updated release, please click here.

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Author

Paul Ogawa

Paul Ogawa is a Senior Regulatory Counsel at Sovos Compliance. As part of the Regulatory Analysis team, his main areas of focus are state and federal tax withholding, the Affordable Care Act (ACA), and Canadian tax information reporting. Prior to Sovos, Paul worked as a litigation attorney in Boston area law firms, representing clients in insurance subrogation claims, family law matters, and employment disputes. Paul is a member of the Massachusetts Bar, earned his B.A. from Brandeis University and his J.D. from the Suffolk University Law School.
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