On May 3, 2013, the Treasury Department issued new regulations that require all taxpayers who have been issued an employer identification number (EIN) to provide additional information to the IRS in the time and manner prescribed by the IRS. Such reporting will not begin before January 1, 2014, in order to give the IRS time to prepare the appropriate form and instructions for such reporting.

The apparent impetus for these regulations is that many applications for EINs have been filed listing people who were only temporarily authorized to act on behalf of the entity applying for the EIN. The IRS wants to be able to identify a true responsible person to be associated with each EIN in order to be able to contact the correct person regarding tax matters related to the entity.

These regulations may create difficulties for organizations such as law, accounting and business management firms that keep track of legal entities for hundreds or even thousands of clients. We will report further on this when the IRS issues the applicable form.