NATP Comments on 2019 Draft Form W-4 and Instructions Letter

On behalf of the members of the National Association of Tax Professionals (NATP), we submitted feedback on the Form W-4, Employee’s Withholding Allowance Certificate, to the IRS and Department of Treasury.

As the largest organization dedicated to excellence in federal tax preparation, we are well placed to provide practical, common sense observations. Our recommendations emphasize the need for a simple Form W-4 that reduces administrative burden, protects the privacy of employees, and avoids the shifting of additional burden to employers.

The form and instructions as currently presented raise a few concerns:

• At a staggering 11 pages of instructions, as compared to four pages in 2018, the burden on both employees and employers has unnecessarily increased.
• The new requirement that employees disclose other household income such as investment income and income from other family members raises privacy concerns by allowing inappropriate disclosures to employers.
• The increased complexity of the new form creates a substantial risk of under withholding.

We understand and appreciate that it has long been the goal of Congress, the Treasury and ultimately the IRS, to simplify the tax code and tax filing in an overriding effort to reduce taxpayer burden. However, the proposed revision to Form W-4 undeniably increases the burden on both employees and employers.

Review the complete letter submitted