Social Security has posted two new forms to be used in its upcoming system for direct deposit of attorney fees. The first is SSA-1694, which is used to supply a taxpayer identification number for a business entity. The second is SSA-1699, by which an attorney would supply information about a professional association and provide direct deposit information. It is unclear whether the SSA-1699 would have to be filled just once or filed separately for each client.
The SSA-1699 has one obvious problem. For the direct deposit information, the form says that "You must be the owner or co-owner of the account" and asks that you check to indicate whether you are. This is a problem for any attorney who works for a professional corporation or who works as an associate attorney anywhere. An associate attorney is an employee of a law firm, rather than a partner or princilpe who has an ownership interest. The form, as currently set up, would probably exclude most attorneys representing Social Security claimants, since most of them are either associate attorneys or attorneys who work for professional corporations. There are other places on the form that suggest confusion about law firm organization. The person filling out the form is asked to check one of two blocks. One is labeled "Sole proprietor or Single-Member LLC/LLP" and the other is "Partner or Salaried Employee." It makes no sense to distinguish between Single-Member and non-Single-Member professional corporations and there are many more designations for professional corporations than LLC and LLP. Also, partners and salaried employees are lumped together, but are rather different ecenomically. This form will have to be redone. Fortunately, this system will not be mandatory for some time.
The SSA-1699 has one obvious problem. For the direct deposit information, the form says that "You must be the owner or co-owner of the account" and asks that you check to indicate whether you are. This is a problem for any attorney who works for a professional corporation or who works as an associate attorney anywhere. An associate attorney is an employee of a law firm, rather than a partner or princilpe who has an ownership interest. The form, as currently set up, would probably exclude most attorneys representing Social Security claimants, since most of them are either associate attorneys or attorneys who work for professional corporations. There are other places on the form that suggest confusion about law firm organization. The person filling out the form is asked to check one of two blocks. One is labeled "Sole proprietor or Single-Member LLC/LLP" and the other is "Partner or Salaried Employee." It makes no sense to distinguish between Single-Member and non-Single-Member professional corporations and there are many more designations for professional corporations than LLC and LLP. Also, partners and salaried employees are lumped together, but are rather different ecenomically. This form will have to be redone. Fortunately, this system will not be mandatory for some time.
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