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APA Comments on the Preliminary 2019 Draft Form W-4 and Instructions

BY: APA Staff | 07/06/18

On July 3, APA submitted detailed comments to the IRS on the preliminary draft 2019 Form W-4, Employee’s Withholding Allowance Certificate, and the related instructions. APA identified several concerns, provided an analysis of the instructions for specific lines, and offered recommendations to improve the form and instructions. The draft Form W-4 has been substantially revised to comply with the Tax Cuts and Jobs Act (TCJA; Pub. L. 115-97). APA has also asked the IRS to publish the final version no later than the end of August so that there is sufficient time to upgrade software systems and payroll processes.

In addition to publishing the form early, APA recommended adding language to the Summary of the Instructions (included with Form W-4) and the separate instructions stating that an employer may require employees to complete a new Form W-4. This would help employers that do not have the resources to implement system upgrades that can accommodate processing of both the old and new Form W-4.

The draft Form W-4 includes lines for information such as nonwage income, income from more than one job and/or a working spouse, itemized deductions, and tax credits. Employees may not know or want to share this information with their employers. The IRS provides the alternative of using the IRS withholding calculator to determine an additional withholding amount to report on the form. APA’s comments offer several recommendations to make the calculator easier to use and to clarify its instructions.

For more information on APA’s comments, see the July 2018 issue of Inside Washington. For a complete overview of the draft Form W-4 and the related instructions, see PAYROLL CURRENTLY, Issue 7, Vol. 26.

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