IRS Practice Unit: FDAP Payments - Statistical Sampling and Projection Procedures (IRC §1441)

Use of statistical sampling in the audit of a U.S. withholding agent (USWA) and associated projection procedures, the IRS Large Business and International Concept Unit outlined in a practice unit released January 22. The IRS noted the usefulness of this method for audits of large entities with a large number of Forms 1042-S, Foreign Person’s U.S. Source Income Subject to Withholding, transactions or payments of Fixed Determinable Annual Periodic (FDAP) income subject to withholding (that may or may not have been reported). [IRS Practice Unit FDAP Payments - Statistical Sampling and Projection Procedures (Jan. 22, 2020)]

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