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Comp Blog

Q&A: Truncating TINs on IRS Forms

By: Danielle Wright

CommentTuesday - January 14, 2014

Q:  Are credit unions allowed to truncate social security numbers on IRS Forms 1099 and 1098?

A:  Yes.  The IRS implemented a pilot program for calendar years 2009 through 2012 authorizing filers of certain information returns to truncate tax payer identification numbers. In January 2013, the IRS issued a Notice of Proposed Rulemaking implementing the pilot program and proposing regulations that create a new taxpayer identification number known as the IRS truncated taxpayer identification number, a TTN.  The TTN displays only the last four digits of an individual’s identifying number and is shown in the format XXX-XX-1234 or ***-**-1234.

Although this proposal has not been finalized, the IRS Office of Chief Counsel of Procedure and Administration told CUNA that “filers may continue to rely on the proposed regulations as they remain in full force and effect absent a final regulation.  Filers will not be penalized for truncating TINs according to those proposed regulations.”

A few highlights from the proposed regulation:

  • The proposal includes all statements in the Forms 1099, 1098, and 5498 series, with the exception of Form 1098-C.  
  • The proposed regulations expand the scope of the pilot program so that filers are permitted to use the TTN on payee statements furnished by paper or electronic means.  
  • Participation in the truncation program is voluntary.  
  • The TTN may be used in lieu of a payee’s SSN, ITIN, or ATIN (IRS adoption taxpayer identification number) – but not a payee’s EIN.  
  • A filer may not truncate its own identifying number on information returns filed with the IRS or payee statements.  

For more information see IRS Notice of Proposed Rulemaking


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