We have been paying an on-call physician under contract for services performed and issuing Form 1099-MISC to him annually under his individual name and corresponding SSN.  We have recently received 2 IRS levies on this individual and have remitted monies to the IRS for services performed but not paid as of the date of the receipt of the levies.  The physician now wants to redo his on-call contract to change the name from his individual name and SSN to a business name with an associated EIN in order to avoid future levies against him individually.  Are there any potential problems with us agreeing to do this?

I am writing an abatement letter to get waived 46 instances on our 972CG for late filing. We discovered certain reportable payments were excluded from our 1099 processing and subsequently filed them 7 months late. My plan is to quote the regulation showing that we know the regulation and show that we corrected the issue immediately to demonstrate we are actively seeking compliance and have a history of compliance.  Is sec 6721 the correct section I should be citing in my letter for late or untimely filing?

One of our Payors changed its name towards the end of 2011. Their Tax ID number stayed the same. We filed the 1042-S and the extension under the old name. We are now in the process of filing the 1042 under the old name as well but wonder if this will cause a problem on the IRS end?

Key here is that the payments to our payees ocurred after the payor changed it's name but we filed the 1042-S under the old payor's name. Do we need to file an ammended return under the new name? Could we be facing penalties?

One of our companies changed its name towards the end of 2011. Their Tax ID number stayed the same. We filed the 1042-S and the extension under the old name. We are now in the process of filing the 1042 under the old name as well but wonder if this will cause a problem on the IRS end? Do we need to file an ammended return under the new name? Could we be looking at penalties?

Back in January of his year I filed an extension of time for the tax year of 2011 for our companies 1099 returns.  Sending the file deadline was 5/2/12 and our original file did not get sent to the IRS until today. 

Do you know what type of penalty fee we will be facing, how much or could we send the IRS a letter asking them to waive the penalty?   What are our options?

Escrow payment to a foreign national:  My company is dealing with the escrow payments on a real estate sale for a Florida property being sold to a US Company.  Unfortunatley, the owners of the property are a Panamanian Company whose principals reside in Greece. 

For the actual real estate payment, the 10% was withheld.  But concerning the other expenses involved in the sale...

Questions:

1) A greek attorney has submitted an invoice for work done to show the Panamanian company is in good standing.  What reporting and withholding responsibilities does my company have in this?  Keep in mind that we only disperse the escrow funds per our clients demands and as determined on the HUD (no oversight).  Who would have the reporting obligations, if not my company?

2) Do any of the normal attorney exceptions apply for foreign payments (bankruptcy attorney or dealing with a closing settlement)?  Or are those exceptions not part of 1042S reporting?

3) How about for settlement exceptions, such as damages to property?  Are those types of settlements still excluded on 1042S reporting?

We received a Notice of Levy 668-A(ICS) from the IRS that is dated 06/07/2011. The 21-day period has now passed, we have not received a release notice and need to pay the taxpayer for work performed after those dates. Are we still obligated to withhold?

We are a mortgage servicing company who completes 1099As in relation to foreclosure sales and 1099Cs for short sales.  When we receive our 972CG penalty notice from the IRS it includes a number of borrowers we have obtained W8-BEN forms from.  I have read that if a foreign person provides a W8-BEN form then they are exempt from back-up withholding and Form 1099 reporting.  So my questions are:

1)  If we have a W8-BEN from a borrower, then are we not required to file a 1099A or 1099C form on that borrower?  SO if there should be a 1099A or a 1099C do we just file nothing?

2)  Also, if we have a borrower with a W8-BEN, what are our reporting requirements for 1098 interest?  Do we have to file a 1042-S rather than a 1098?

Who do I contact at the IRS if I have not received our Proposed Penalty notice?  We generally have it by now so I am concerned.

Will 1042S forms be included on the IRS penalty notice 972?  if so will they begin with the 2010 reporting or 2011 reporting?