Sup Stmnt SS4 and SS4PR

Sup Stmnt SS4 and SS4PR.doc

Forms SS-4 - Application for Employer Identification Number; SS-4PR, Solicitud de Numero de Identificacion Patronal (EIN)

OMB: 1545-0003

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SUPPORTING STATEMENT

(Forms SS-4 and SS-4PR)

OMB # 1545-0003


  1. CIRCUMSTANCES NECESSITATING COLLECTION OF INFORMATION


Sections 6011 and 6109 of the Internal Revenue Code, section 31.6011(b) of the Employment Tax Regulations, and section 301.6109‑1 of the Procedures and Administration Regulations require certain taxpayers to have an employer identification number for use on returns, statements, or other documents. Form SS‑4 and Form SS‑4PR are used by these taxpayers to obtain an employer identification number.


2. USE OF DATA


The information is used by the IRS and the SSA in tax administration and by the Bureau of the Census for business statistics.


3. USE OF IMPROVED INFORMATION TECHNOLOGY TO REDUCE BURDEN


Application for EIN, which has low volume compared to cost of electronic enabling.


  1. EFFORTS TO IDENTIFY DUPLICATION


We have attempted to eliminate duplication within the agency wherever possible.

5. METHODS TO MINIMIZE BURDEN ON SMALL BUSINESSES OR OTHER SMALL ENTITIES


Not applicable.


  1. CONSEQUENCES OF LESS FREQUENT COLLECTION ON FEDERAL PROGRAMS OR POLICY ACTIVITIES


Not applicable.


7. SPECIAL CIRCUMSTANCES REQUIRING DATA COLLECTION TO BE INCONSISTENT WITH GUIDELINES IN 5 CFR 1320.5(d)(2)


Not applicable.








  1. CONSULTATION WITH INDIVIDUALS OUTSIDE OF THE AGENCY ON AVAILABILITY OF DATA, FREQUENCY OF COLLECTION, CLARITY OF INSTRUCTIONS AND FORMS, AND DATA ELEMENTS


Periodic meetings are held between IRS personnel and representatives of the American Bar Association, the National Society of Public Accountants, the American Institute of Certified Public Accountants, and other professional groups to discuss tax law and tax forms. During these meetings, there is an opportunity for those attending to make comments regarding Forms SS-4 and SS-4PR.


In response to the Federal Register notice dated August 27, 2014, (79 FR 51225), we received no comments during the comment period regarding Forms SS-4 and SS-4PR.


9. EXPLANATION OF DECISION TO PROVIDE ANY PAYMENT OR GIFT TO RESPONDENTS


Not applicable.


  1. ASSURANCE OF CONFIDENTIALITY OF RESPONSES


Generally, tax returns and tax return information are confidential as required by 26 USC 6103.


11. JUSTIFICATION OF SENSITIVE QUESTIONS


No personally identifiable information (PII) is collected.


12. ESTIMATED BURDEN OF INFORMATION COLLECTION


The burden estimate is as follows:


Number of Time per Total

Responses Response Hours


Form SS-4 1,546,042 .56 865,784

Form SS-4PR 66,666 .56 37,333 ___________________________________________

Total 1,612,708 903,117













Estimates of the annualized cost to respondents for the hour burdens shown are not available at this time.

The following regulations are related regulations which impose no additional burden. Please continue to assign OMB number 1545-0003 to these regulations.


31.6011(b)

46.6109-1

301.6109-1 through 3


13. ESTIMATED TOTAL ANNUAL COST BURDEN TO RESPONDENTS


As suggested by OMB, our Federal Register notice dated August 27, 2014, (79 FR 51225), requested public comments on estimates of cost burden that are not captured in the estimates of burden hours, i.e., estimates of capital or start-up costs and costs of operation, maintenance, and purchase of services to provide information. However, we did not receive any response from taxpayers on this subject. As a result, estimates of the cost burdens are not available at this time.


14. ESTIMATED ANNUALIZED COST TO THE FEDERAL GOVERNMENT


After consultation with various functions within the Service, we have determined that the estimated annual cost associated with developing, printing, processing, distributing Form SS-4 and SS-4PR is $2,244,744.


  1. REASONS FOR CHANGE IN BURDEN


Due to a change in agency estimate, Forms SS-4 and SS-4PR are now estimated using the Special Business forms designation, which decreased the total burden to 903,117 hours. This designation better and more consistently reflects the actual user experience with the form. The previous designation of Regular Business Form dramatically overestimated the amount of time needed to learn about the form and research code sections each time the form was filled out. This change will result in an estimated decrease of 15,038,797 hours.


16. PLANS FOR TABULATION, STATISTICAL ANALYSIS AND PUBLICATION


Not applicable.


  1. REASONS WHY DISPLAYING THE OMB EXPIRATION DATE IS INAPPROPRIATE


See attachment.


  1. EXCEPTIONS TO THE CERTIFICATION STATEMENT


Not applicable.




Note: The following paragraph applies to all of the collections of information in this submission:


An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless the collection of information displays a valid OMB control number. Books or records relating to a collection of information must be retained as long as their contents may become material in the administration of any internal revenue law. Generally, tax returns and tax return information are confidential, as required by 26 U.S.C. 6103.


OMB EXPIRATION DATE


We believe the public interest will be better served by not printing an expiration date on the form(s) in this package.


Printing the expiration date on the form will result in increased costs because of the need to replace inventories that become obsolete by passage of the expiration date each time OMB approval is renewed. Without printing the expiration date, supplies of the form could continue to be used.


The time period during which the current edition of the form(s) in this package will continue to be usable cannot be predicted. It could easily span several cycles of review and OMB clearance renewal. In addition, usage fluctuates unpredictably. This makes it necessary to maintain a substantial inventory of forms in the supply line at all times. This includes supplied owned by both the Government and the public. Reprinting of the form cannot be reliably scheduled to coincide with an OMB approval expiration date. This form may be privately printed by users at their own expense. Some businesses print complex and expensive marginally punched continuous versions, their expense, for use in their computers. The form may be printed by commercial printers and stocked for sale. In such cases, printing the expiration date on the form could result in extra costs to the users.


Not printing the expiration date on the form(s) will also avoid confusion among taxpayers who may have identical forms with different expiration dates in their possession.


For the above reasons we request authorization to omit printing the expiration date on the form(s) in this package.




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