NASCOE has received several submissions concerning PL-271 and the AGI process in general. We have been sharing these concerns with WDC through various channels. One particular concern revolved around a February 26th deadline to begin enforcing that IRS determinations or SED determinations be received within 120 days of the producer’s certification. While discussions continue, WDC has issued the following response:
NATIONAL OFFICE RESPONSE:
Notice PL-271 provided information on AGI compliance and the upcoming start of a 120-day time clock for overpayments due to AGI. This time clock was expected to begin February 26, 2016. The impacts of the 120 day time clock are still under discussion at the national office and as a result, the effective date will be delayed. Additional information will be forthcoming.