Anybody at Social Security want to explain why this is a big secret?
Identification Number AM-09032 SEN Effective Date: 02/23/2009
Intended Audience: All RCs/ARCs/ADs/FOs/TSCs/PSCs/OCO/ODARHQ
Originating Office: DCBFM OFPO
Title: Delay in Issuance of Forms 1099-MISC to Claimant Representatives
Type: AM - Admin Messages
Program: All Programs
SENSITIVE - NOT TO BE SHARED WITH THE PUBLIC
Retention Date: August 15, 2009
This instruction is intended to address the inquiries from attorneys, eligible non-attorneys, and affiliated entities who were expecting to receive a Form 1099-MISC by January 31, 2009, to report the aggregate fees received via direct payment from SSA during 2008.
Background
Sections 6041 and 6045(f) of the Internal Revenue Code, as implemented by 26 CFR 1.6041-1, require SSA to issue a Form 1099-MISC to each representative who receives, by direct payment from SSA, aggregate fees of $600 or more in the prior calendar year. To comply with this requirement, we developed a new 2-step registration requirement (using the SSA-1699 (Request for Appointed Representatives Direct Payment Information) and SSA-1695 (Identifying Information for Possible Direct Payment of Authorized Fees)) for representatives appointed on or after January 1, 2007, who had not waived direct fee payment, and for attorneys for whom a Federal court approved a fee on or after January 1, 2007. We also developed voluntary registration (using the SSA-1694 (Request for Business Entity Taxpayer Information) for affiliated entities who wished to have the payments reported as taxable income to the entity rather than to the representative.
General information
We had targeted the first issuance of these required Forms 1099-MISC for January 2009 to report the direct fee payments made during calendar year 2008. However, due to unexpected systems limitations, an executive decision has been made to delay issuance of Forms 1099-MISC to representatives for one year. Therefore, we are currently targeting the initial issuance of these Forms 1099-MISC for January 2010 in order to report direct fee payments made during calendar year 2009.
I'm starting to suspect that the "Sensitive" annotation is programmed as part of the header for all issuances--how else to explain some of this ridiculous supposed secrecy?
ReplyDeleteI think it could be CYA on the part of newer people in jobs writing EMs and AMs. You don't want to blow you chance for an award or promotion on something you posted on Policy Net that comes back to bite you in the butt.
ReplyDeleteI'm sure no one has ever got in trouble for making something sensitive, even when it doesn't make any sense.
Everything is a secret with SSA managers. The governmental transparency being touted by the Obama Administration is going to be a bitter pill to swallow by the SSA brass. The seriousness of the "transparency" policy will be tested by these folks. Maybe with good reason...WHAT IF SOMEONE FINDS OUT WHAT THEY ARE REALLY DOING???????
ReplyDelete