What This Notice Means

CP2100 goes to payers, not payees. It says the payee name and taxpayer identification number (TIN) on information returns you filed are missing or don't match IRS records. The notice includes a list of the missing, incorrect, or not currently issued TINs.

CP2100 is not itself a B notice. It is the IRS telling you which payees may need one. The IRS issues CP2100 when a payer filed 50 or more returns with errors and CP2100A when there are fewer than 50. The instructions are the same. These notices go out twice a year, in October and the following April.

Missing or Obviously Incorrect TINs

A TIN is obviously incorrect if it isn't 9 digits or contains something other than numbers. For these payees:

  • Begin backup withholding immediately if you haven't already, even on a one-time payment.
  • Keep withholding until the payee gives you a TIN.
  • 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.

TINs That Don't Match IRS Records

  • Compare the notice list to your records.
  • If they match, send the appropriate B notice to the payee right away. Publication 1281 has the B notices and tells you which one to use.
  • If your records don't match the list, the cause may be a recent update, an error in what you filed, or an IRS processing error. Correct or update your records.
  • If the payee doesn't respond, start backup withholding on future payments no later than 30 business days after you received the CP2100.
  • When the payee sends a TIN, stop backup withholding no later than 30 calendar days after you receive it.

Don't call or write the IRS to say you corrected your records or received a new TIN.

Withholding and Reporting

The backup withholding rate is 24%. Deposit it under your monthly or semiweekly schedule and report it on Form 945 using the same name and EIN you used on the information returns. If you were required to withhold and didn't, the business can be held liable for the amount that should have been withheld.

Going Forward

Payers of most Forms 1099 can apply for the IRS TIN Matching program to check TINs before filing. Keep your address current with Form 8822-B so these notices reach you.

If you received a CP2100 and need help with B notices or backup withholding, call us at (813) 229-7100.