IRS CP2100: what it means and what to do

What this notice means

The IRS says a CP2100 or CP2100A means payee names and TINs on your information returns are missing or do not match its records, and you may need to start backup withholding.

“The payee's name and taxpayer identification number (TIN) on your information return is missing or doesn’t match our records. You may need to begin backup withholding on these payee accounts if you haven't already done so.”
IRS, Understanding your CP2100 or CP2100A notice

What to do

The IRS says to compare your records to the notice list and, if they match, send the appropriate "B" notice to the payee.

“Compare your payee records to the notice list. If the notice and your records match, send the appropriate "B" notice to the payee. If the notice and your records don’t match, this could be because of a recent update, an error in the information you filed, or an IRS processing error. If this has happened, you only need to correct or update your records.”
IRS, Understanding your CP2100 or CP2100A notice

Your deadline

The IRS says if a payee does not respond to the "B" notice, you must begin backup withholding no later than 30 business days after receiving the CP2100 or CP2100A.

“If the payee doesn’t respond, you must begin backup withholding from any future payments you make to them no later than 30 business days after you received the CP2100 or CP2100A notice.”
IRS, Understanding your CP2100 or CP2100A notice

After you respond

The IRS says not to send it a payee's corrected TIN or contact it about the correction; instead correct your records and stop backup withholding on future payments.

“No, don’t send this information to us or contact us to say you have the correct TIN. Correct your records and stop backup withholding on future payments to that payee.”
IRS, Understanding your CP2100 or CP2100A notice

What happens if you ignore it

The IRS says you must make up to three requests for a missing TIN to avoid a penalty for not including a TIN on the information return.

“Begin backup withholding immediately if you haven’t already. Most of the time, when a payer makes a payment to a payee who didn’t supply their TIN or supplied an obviously incorrect TIN, the payer must backup withhold when they make the payment. You must make up to three requests for the TIN (initial, first annual, second annual) to avoid a penalty for not including a TIN on the information return.”
IRS, Understanding your CP2100 or CP2100A notice

A related right

The IRS says payers and their authorized agents who file information returns can use TIN Matching if listed in its Payer Account File database.

“TIN Matching is only for payers and their authorized agents that submit information returns. To use this service, a payer must be listed in the IRS Payer Account File (PAF) database. Payers are added to the database if they filed Forms 1099 within the last 2 years to report backup withholding.”
IRS, Taxpayer Identification Number (TIN) Matching

More from the IRS on this notice

The IRS says a CP2100 goes to payers with 50 or more information returns with errors and a CP2100A to payers with fewer than 50; the instructions are the same.

“We issue a CP2100 when the payer has filed 50 or more incorrect information returns with errors. We issue a CP2100A when the payer has filed less than 50 information returns with errors.”
IRS, Understanding your CP2100 or CP2100A notice

The IRS says it issues CP2100 and CP2100A notices twice a year, in October and the following April.

“When does IRS issue CP2100 and CP2100A notices? We issue CP2100 and CP2100A notices twice a year, in October and the following April.”
IRS, Understanding your CP2100 or CP2100A notice

The IRS says the current backup withholding rate is 24% of payments to the payee, and withheld amounts must be reported on Form 945.

“The current backup withholding rate is 24% of payments you make to a payee. You must report the backup withholding you collect by filing Form 945, Annual Return of Withheld Federal Income Tax PDF.”
IRS, Understanding your CP2100 or CP2100A notice

The IRS says the payer sends a First "B" Notice with a Form W-9 the first time a payee is listed, and a Second "B" Notice if the payee is listed again within three years.

“The payer must send the First “B” Notice and a Form W-9 to a payee the first time a payee is listed on the CP2100 or CP2100A notice. The payer must send the Second “B” Notice to a payee after the payee is listed on a CP2100 or CP2100A notice a second time within a three-year period.”
IRS, Backup withholding “B” program

The IRS says a payee answers a First "B" Notice with a signed Form W-9, but a Second "B" Notice requires a Social Security card copy or IRS Letter 147C.

“For the First “B” Notice, a properly completed and signed Form W-9 (or acceptable substitute). For the Second “B” Notice, the payee must provide a copy of their Social Security card, or Letter 147C from the IRS verifying the name and the number are correct (EIN).”
IRS, Backup withholding “B” program

The IRS says that once a payee sends their TIN, you must stop backup withholding on their payments no later than 30 calendar days after you receive it.

“When the payee sends you their TIN, you must stop backup withholding on any payments you make to them no later than 30 calendar days after you receive their TIN.”
IRS, Understanding your CP2100 or CP2100A notice

Before you reply

1. Compare the notice with your own records for the tax year it names.
2. Note the date on the notice and the response date it gives.
3. Answer by the method and address the notice gives; keep a copy of everything you send.
4. If the notice could be fraudulent, contact the IRS through the phone number or address on IRS.gov, not one printed on a suspicious letter.

Common questions

How long do I have to respond to an IRS CP2100?

The IRS says if a payee does not respond to the "B" notice, you must begin backup withholding no later than 30 business days after receiving the CP2100 or CP2100A.

What happens if I ignore a CP2100?

The IRS says you must make up to three requests for a missing TIN to avoid a penalty for not including a TIN on the information return.