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Comply Connect – September 2023 – Issue 4

September Comply Connect
David Marley CEO

We are excited to announce that we have officially joined the SAP Ariba partnership network. We started this partnership with one shared goal in mind, and that is to continue to enhance, automate and simplify the onboarding process. Through this collaboration, Comply Exchange's cutting-edge documentation collection and validation technology will extend its reach to millions of businesses worldwide, offering current SAP users and partners the opportunity to effortlessly integrate our product into their existing onboarding workflows.

COMING UP IN october 2023:

COMING UP IN October 2023:

Money 20/20 conference

We are excited to announce our attendance at this year’s Money 20/20 conference October 22 – 25 in Las Vegas! We look forward to connecting and engaging with some of the world’s largest Fintech companies. 
If you would like to get in touch with us ahead of the conference to schedule a meeting, you can do so through the Money 20/20 networking app which is now LIVE. Simply search for our profile in the directory, and we would be delighted to connect. 
For those interested in attending the event, passes are still available and can be acquired here. 

Sovos Comply and Connect Conference

We will be attending Comply and Connect 2023 hosted by Sovos. Save the date for the industry’s premier conference for information on emerging trends in tax, regulatory reporting and compliance. 

Join us from October 23-25 at the Hyatt Regency in Austin, TX. 

If you have not signed up already, you can register here. 


IRS Draft Forms and Instructions  

During September, the IRS published the following DRAFT forms and instructions: 


Issue Number 2023-165

On September 6, the IRS issued IR-2023-165 reminding taxpayers of the following: 

  • For taxpayers who pay estimated taxes, the deadline to submit their third quarter payment was Sept. 15, 2023.
  • The IRS provided the below general rule of thumb for whether a taxpayer should make estimated tax payments, noting they should if they expect: 
    • To owe at least $1,000 in taxes for 2023 after subtracting their withholding and tax credits. 
    • Their withholding and tax credits to be less than the smaller of: 
      • 90% of the tax to be shown on their 2023 tax return or 
      • 100% of the tax shown on their complete 12-month 2022 tax return.
  • For payments received in January 2023, taxpayers who were paid over $600 by payment apps and online marketplaces or received any amount by payment cards could receive a Form 1099-K, Payment Card and Third Party Network Transactions, starting January 2024.

Issue Number 2023-13 

The IRS released Issue Number 2023-13 alerting Qualified Intermediaries (QI) (including Qualified Derivatives Dealers), Withholding Foreign Partnerships (WP) and Withholding Foreign Trusts (WT) of the application deadline for the 2023 year. All applicants wishing to have an agreement in effect for 2023 must submit their applications through the Qualified Intermediary, Withholding Foreign Partnership, Withholding Foreign Trust Application & Account Management System (QAAMS) no later than October 27, 2023. If required for Chapter 4 purposes, a GIIN must have been obtained prior to application submission. 

Applications submitted after October 27, 2023, will not be processed. If an applicant is unable to submit an application before the October deadline, then they will need to wait until January 1, 2024, to submit for the 2024 year. 

Publication 1167 

On September 13, the IRS released a draft version of Publication 1167, General Rules and Specifications for Substitute Forms and Schedules. Changes include: 

  • Forms 5300 and 5307 can no longer be submitted as substitute forms – Forms 5300 and 5307 must be submitted electronically through
  • Form 8905 is discontinued – Form 8905 is discontinued and can no longer be filed with Forms 5300 and 5307. 

Publication 1220

On September 18, the IRS released a new version of Publication 1220, Specifications for Electronic Filing of Forms 1097, 1098, 1099, 3921, 3922, 5498, and W-2G. Changes include: 

  • Information on IRIS, Information Returns Intake System, Taxpayer Portal, which is a free online system that allows users to electronically file information returns and automatic extensions of time to file. IRIS requires its own TCC (Transmitter Control Code).
  • Information on the threshold for filing returns and other documents electronically. The regulations will require filers of 10 or more information returns in a calendar year beginning in 2024, tax year 2023, to file those information returns electronically.
  • Additional resources for IRIS and Publication 5717, IRIS Taxpayer Portal User Guide added to table.
  • Changes to the participating states and codes in the CF/SF program.
  • Added: District of Columbia (42) and Pennsylvania (11)
  • Clarifying response provided for Part B. Sec. 1 Information Returns (IR) Application for Transmitter Control Code (TCC), .05 Do I Need More than One TCC?
  • Added: “A TCC used to file Forms 1097, 1098, 1099, 3921, 3922, 5498, and W2G can be used to submit 1,000 files per year. If the TCC exceeds 1,000 files, an additional TCC can be requested via the IR Application for TCC.” 


OECD: Updates to Tax Residency, Tax Identification Numbers, & Legislation 

The OECD published updated information on Tax Identification Numbers, Tax Residency rules and primary and secondary legislation for various jurisdictions. Tax Identification Number information was modified for Jamaica, Oman, Lithuania, Nigeria, Ukraine, and Kenya. Tax Residency rules were modified for Jamaica, Oman, Lithuania, Nigeria, Ukraine, Bulgaria and Kenya. Legislation was modified for Kuwait, Jamaica, Oman, Ukraine, and Rwanda.  

Ireland: Revenue eBrief No. 198/23 

On September 19, 2023, the Ireland Revenue Commissioners published Revenue eBrief No. 198/23 informing Reporting Financial Institutions of updates to the Tax and Duty Manual Part 38-03-23, which provides guidance on domestic implementation issues relating to the Common Reporting Standard. Updates include editorial changes and deletion of obsolete material in paragraphs 18 and 19.  

Switzerland: Updated list of AEOI Partner States 

The Federal Tax Administration of Switzerland updated its list of AEOI partner states.  

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