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A third different 941 for 2020


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The IRS dropped a third version of the 2020 941 yesterday.  The new version is for Q3 and Q4, with some changes made for the Sept-Dec SS deferral option.

While I have no inside information, I suspect any of the three revisions can be used, as long as the figures are correct, and the revision used will handle the employer's needs for the quarter being reported.  It appears the IRS will differentiate the revisions via the "95" code at the top right of each page.

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After review and implementation (only one person's opinion!) it appears the second revision may still work, unless the employer elected to defer (the Presidential memo).  Page 3 has a different "95" code, which should allow the scanning software to interpret each revision appropriately.  Of course, that is using logic, which may not apply in this case, so use the old revision at your own risk.

Personally, I mailed my form yesterday, before the new form dropped (I did not defer), so we will see if it bounces back.

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I've already filed all my 941s for clients.  Used the April revision before they had a chance to revise it and mess it up even further.  None of mine chose to participate in the deferral, so most of what I have are zeroes and empty numbers for Family Medical Leave, Sick Leave, and all the special features that few employers register for.

I understand that after the Executive Order, all Federal Employees were defaulted into the deferral, but don't know whether they could choose to bail out.  My non-political view of the deferral is that it is a very bad idea.  What was unclear to me was the unclear collection responsibility of the employer if an employee quit in December.  The mere mention of this to my clients pretty well scared them off.

 

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I have a customer who sent in the Q1 layout for Q2, and it was rejected.  If (now un)common sense were to be used, the Q2 form can still be used for Q3, but only time will tell what those folks in the forms design and processing locations have determined.  The instructions for Q2 state not to use the Q1 form for Q2, but there is nothing that specific in the Q3 instructions (that I noticed).

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The third version of the 941 was not a big programming change.  The only issue was the late release of the final version means many, like me, already submitted Q3 before the new form was available (since so few "memo" deferred).

The 944 and 943 will also be different, with an additional page for each...

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