What IRS Form 945 (2019) Is For

Form 945 is the Annual Return of Withheld Federal Income Tax for reporting federal income tax withholding from nonpayroll payments (IRS Instructions for Form 945 (2019)). Entities must file if they withheld federal income tax from pensions, annuities, IRA distributions, military retirement, gambling winnings, Indian gaming profits, backup withholding, or certain voluntary withholding elections during 2019.

When You'd Use Form 945 for 2019 (Late or Amended Filing)

You would file Form 945 for 2019 as a late return if you never filed but had nonpayroll withholding tax liability that year, typically after receiving IRS notices about unfiled returns or balance due assessments. For amended returns, use Form 945-X to correct administrative errors where the tax you reported differs from what you actually withheld (IRS Instructions for Form 945-X). Late filers may discover the need when conducting compliance reviews, receiving IRS correspondence, or during tax professional consultations. Note that refund claims must be filed within three years of the original due date or two years after paying the tax, whichever is later.

Key Rules Specific to 2019

The 2019 Form 945 was due January 31, 2020, with an extension to February 10, 2020, if all deposits were made timely (IRS Instructions for Form 945 (2019)). Electronic filing and Electronic Federal Tax Payment System (EFTPS) deposits were required for federal tax deposits. The $2,500 minimum threshold for monthly deposit requirements applied, and entities exceeding $50,000 in prior year liability used semiweekly deposit schedules. Filing addresses differed based on whether payment accompanied the return, with specific routing for exempt organizations and governmental entities.

Step-by-Step (High Level)

• Gather your 2019 tax account transcript from IRS.gov or by calling 800-908-9946 to understand any prior filing history and account status
  
  
• Obtain the correct 2019 version of Form 945 from IRS.gov/pub/irs-prior/ rather than current year forms
  
  
• Complete all required sections including federal income tax withheld (line 1), backup withholding (line 2), and monthly liability schedule if applicable (line 7 or Form 945-A)
  
  
• Attach Form 945-A if you were a semiweekly depositor or accumulated $100,000+ in any month during 2019
  
  
• Mail to the appropriate processing center address based on your location and whether you're including payment (see 2019 instructions for specific addresses)
  
  
• Keep copies of all documents for your records, as the IRS recommends retaining employment tax records for at least four years
  
  

Common Mistakes and How to Avoid Them

• Wrong form version: Using current year Form 945 instead of the 2019 version—always download the specific tax year form from IRS.gov/pub/irs-prior/
  
  
• Mixing payroll and nonpayroll withholding: Reporting wage withholding (Form W-2 amounts) on Form 945—only report nonpayroll payments like pensions, gambling, and backup withholding
  
  
• Incorrect deposit schedule determination: Misunderstanding monthly vs. semiweekly deposit requirements—review your 2018 Form 945 liability to determine 2019 schedule
  
  
• Missing Form 945-A: Failing to attach required monthly liability detail when you're a semiweekly depositor or hit the $100,000 threshold
  
  
• Incomplete third-party designee section: Not properly authorizing representatives to discuss your return with the IRS when using tax professionals
  
  
• Using wrong correction form: Filing amended Form 945 instead of Form 945-X for administrative errors—Form 945-X is specifically designed for corrections
  
  

What Happens After You File

The IRS typically processes Form 945 within 6-8 weeks, though late returns may take longer due to additional compliance reviews (IRS Instructions for Form 945 (2019)). You may receive notices requesting additional information, assessment notices for penalties and interest, or acknowledgment of your filing. If you owe money, you can request an installment agreement using Form 9465 or apply online if you owe $25,000 or less and can pay within 24 months. For disagreements with penalties or assessments, you have appeal rights and can request penalty abatement using Form 843 if you have reasonable cause. The IRS charges interest on late payments and may assess failure-to-file penalties of 5% per month up to 25% of unpaid tax.

FAQs

Can I still get a refund from my 2019 Form 945?

Generally no, as the three-year statute of limitations for refund claims expired in 2023. However, certain exceptions may apply for specific circumstances—consult a tax professional.

What penalties apply to late filing of 2019 Form 945?

The failure-to-file penalty is 5% of unpaid tax per month (maximum 25%), plus failure-to-pay penalty of 0.5% per month. Interest accrues on both taxes and penalties from the original due date.

Do I need my original 2019 records to file late?

While helpful, you can request account transcripts from the IRS and use information returns (Forms 1099-R, W-2G, etc.) to reconstruct your withholding amounts.

Should I also amend my state returns?

State filing requirements vary by jurisdiction. Most states don't have equivalent forms to federal Form 945, but check with your state tax authority about any required filings for nonpayroll withholding.

Can I e-file a late 2019 Form 945?

Electronic filing availability for prior year returns is limited. Most late 2019 returns must be filed on paper using the addresses specified in the 2019 instructions.

What if I discover I never needed to file Form 945 for 2019?

If you had no nonpayroll withholding liability, you weren't required to file. However, if the IRS has assessed you for non-filing, you may need to respond with documentation proving no filing requirement existed.

How long will the IRS keep pursuing a 2019 Form 945?

The IRS generally has 10 years to collect assessed taxes from the assessment date. For unfiled returns, there's no statute of limitations on assessment until a return is filed.

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