IRS notice
IRS Notice CP2100 or CP2100A: What It Means and How to Respond
Sent to payers whose information returns had missing, incorrect or mismatched payee names and TINs; it starts the B notice and backup withholding process.
Reply by the date on the notice
If a payee on the list does not respond to your B notice, the IRS says to start backup withholding on that payee no later than 30 business days after you received the CP2100 or CP2100A.
CP2100 and CP2100A go to businesses that filed information returns, such as Forms 1099, where a payee's name and taxpayer identification number were missing or did not match IRS records. Compare the list with your records, send a B notice to each payee whose details match your files, and begin backup withholding if the payee does not fix it; you do not reply to the IRS.
What this notice is telling you
- Some information returns you filed had a payee TIN that was missing, obviously incorrect, or did not match the name in IRS records.
- CP2100 is sent when 50 or more of your returns are affected; CP2100A when fewer than 50 are. The instructions are the same.
- The IRS mails these notices twice a year, in October and the following April.
- You may now have to send B notices to payees and backup withhold on future payments to some of them.
- This is not a bill, and the IRS does not want a call or letter telling it you corrected your records.
What to do
Sort the list into two groups
Separate payees whose TIN is missing or obviously incorrect (not nine digits, or containing anything other than numbers) from payees whose TIN looks valid but did not match IRS records.
Start withholding on missing or obviously incorrect TINs
For those payees, begin backup withholding immediately if you have not already, and keep making the initial, first annual and second annual requests for the TIN.
Check mismatches against your own files
If your records differ from the list, the error may be yours or a processing error, so correct your records. If your records match the list, send the payee the appropriate B notice right away.
Track responses and deadlines
Start backup withholding no later than 30 business days after you received the notice if the payee has not responded. Stop no later than 30 calendar days after you receive a corrected TIN.
Deposit and report what you withhold
Deposit backup withholding under your monthly or semiweekly schedule and report it on Form 945, filed under the same name and EIN used on the information returns.
First B notice or second B notice
| First B notice | Second B notice | |
|---|---|---|
| When it applies | The first time a payee appears on a CP2100 or CP2100A | The payee appears on a CP2100 or CP2100A a second time within a three-year period |
| What you enclose | A Form W-9 for the payee to complete | No Form W-9 |
| What stops backup withholding | A properly completed and signed Form W-9 or acceptable substitute | A copy of the payee's Social Security card, or IRS Letter 147C for an EIN |
How backup withholding works for this notice
Backup withholding is currently 24% of each reportable payment to the payee. For a missing or obviously incorrect TIN, you withhold from every payment, including one-time payments, until you receive the TIN, unless you had the TIN when you paid and simply left it off the return, or it was dropped during electronic transmission. When a payee gives you corrected information, update your records and stop withholding on future payments; do not send the corrected TIN to the IRS.
Haigler CPA Group can review the CP2100 list against your vendor records, help you prepare the B notices and the Form 945, and correct your process before next year's filings. Where 1099s were produced by your accounting software or a payroll provider, we work from those files; we do not run payroll.
Avoiding the same notice next year
- Collect a signed Form W-9 from each vendor before the first payment, not at year end.
- Use the IRS TIN Matching program, available to payers of most Forms 1099, to check names and TINs before filing.
- Keep the TIN requests you send; the IRS ties penalty relief for missing TINs to making the required solicitations.
Want a CPA to deal with it?
Bring the notice to a free consultation, in person on James Island or by video. We read it with you, tell you what it means for your account and, if you want us to, take over the response once you sign Form 2848.
Business Tax — Year-round planning, corporate returns, pass-through entities and multi-state compliance.
By Haigler CPA Group. Updated . Notices are revised from time to time, so go by the wording and dates on your own notice. The information on this site is general in nature and is not tax, legal, or accounting advice for your situation. Tax law changes and the right answer depends on facts we would need to review with you. Please speak with a qualified professional before acting on anything you read here.
Questions about CP2100 / CP2100A
What is the difference between CP2100 and CP2100A?
Only the number of affected returns. CP2100 goes to payers with 50 or more information returns listed, CP2100A to payers with fewer than 50. What you must do is the same.
Do we need to send corrected 1099s to the IRS?
The CP2100 page tells you to update your records and not to call or write the IRS to say you have corrected them. Ask your preparer whether a particular return also needs a correction filing.
Can we be penalized for the mismatches?
The IRS says you can face a penalty for failing to include a TIN on an information return if you did not make the required TIN requests. Making and documenting the initial and annual solicitations is how a payer protects itself.
We did not receive the notice but think one was sent. How do we get a copy?
The IRS lists 866-455-7438 for copies, weekdays 8:30 a.m. to 4:30 p.m. Eastern. Notices go to your address of record, so file Form 8822-B if your business address changed.
Other notices
- CP259: Business return not filedThe IRS shows a business return as required for a period but not filed; there is one notice per form and period.
- CP161: Unpaid balance on a business tax accountA bill for an unpaid balance on a business tax account, often after a return was filed without full payment or deposits came up short.
- IRS notice lookupEvery IRS notice carries a code. Find yours below to see what it generally means, which date matters, and what to do before that date passes.
Talk to a tax expert
Tell us what you are dealing with and we will tell you how we would handle it.