06 February 2020

Wisconsin will allow for truncation of Social Security Number on employee copy of Form W-2

The Wisconsin Department of Revenue announced that it will conform to IRS final regulations that provide, effective with the 2020 Forms W-2 filed in 2021, a truncated Social Security Number (SSN) may be used on copies provided to employees.

The Department clarifies that:

  • Employers may not truncate the employee SSN on copies of Forms W-2 filed with the Department.
  • Employers may not truncate their own taxpayer identification number on any forms given to employees or filed with the Department.

Background

In T.D. 9861, the IRS issued final regulations that give employers the option of truncating the SSN on those copies of Forms W-2, Wage and Tax Statement, that are furnished to employees effective with returns and statements required to be filed and furnished after December 31, 2020. The provision also applies to employee copies of Forms W-2c, Corrected Wage and Tax Statement.

The IRS clarifies that the option of using the truncated taxpayer identification number (TTIN) applies only to Forms W-2 required under IRC Sections 6051(a), 6051(f)(2) and 6052(b), but not to other documents, returns or statements that specify the requirement for the SSN. Additionally, the full SSN must appear on copies of Forms W-2/W-2c filed with the Social Security Administration. The TTIN is the last four digits of the SSN.

Ernst & Young LLP insights

During the rulemaking process, the IRS gathered public comments. Some commentators expressed concern that state and local governments may require the SSN be provided on the employee copy of the Form W-2, increasing the burden for employers with reporting requirements in multiple jurisdictions. The IRS responded that employers facing a burden due to differing state and local rules may opt not to truncate the SSN on all employee Forms W-2 provided.

Employers will need to confirm if state and local taxing authorities have adopted the revised IRS regulations before giving employees Form W-2 copies with truncated SSNs. It could take a few years before some states and locales conform to the new IRS rule.

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Contact Information
For additional information concerning this Alert, please contact:
 
Workforce Tax Services - Employment Tax Advisory Services
   • Kenneth Hausser (kenneth.hausser@ey.com)
   • Debera Salam (debera.salam@ey.com)
   • Kristie Lowery (kristie.lowery@ey.com)

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ATTACHMENT

EY Payroll News Flash

Document ID: 2020-0319