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Ezel / IRS Rulings / 201603027
Chief Counsel Advice 201603027 Released January 15, 2016 Advice

Estimated-tax ruling does not apply to Form 1042

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This page covers one taxpayer's ruling from 2016, which can't be cited as precedent. Ezel answers your situation under the current Code and IRS guidance, with citations.

Currency note: this determination was released in 2016
Statutory amendments, regulation changes, court decisions, or later IRS guidance may have changed the analysis since then. Treat this page as historical context, not current tax advice. Verify current law before relying on any specific rule, threshold, or position mentioned here.
Not precedent. Under 26 U.S.C. § 6110(k)(3), this written determination may not be used or cited as precedent. It resolved one taxpayer's situation on its specific facts, and identifying details were redacted by the IRS before release. The official IRS release (linked on this page as a PDF) is the authoritative source.
About this page: The plain-English summary and ruling snapshot below were written by Ezel based on the official IRS release. The full text is the IRS's own document.
View official IRS release (PDF)

Plain-English summary

Chief Counsel considered whether Revenue Ruling 99-40 applies to a credit election involving a withholding tax return on Form 1042. Counsel advised that the ruling's treatment of unpaid estimated-tax installments does not apply. Form 1042 filers are not required to make estimated income-tax payments, so the premise of that ruling is absent.

Ruling snapshot

  • Question: Does Revenue Ruling 99-40 apply to Form 1042 as it relates to unpaid estimated-tax installments?
  • Outcome: No, because Form 1042 filers do not make estimated income-tax payments
  • Key authorities: IRC § 6601; Rev. Rul. 99-40

Full text (IRS public release)

ID: CCA_2015112316071644 [Third Party Communication:

UILC: 6601.02-01 Date of Communication: Month DD, YYYY]

Number: 201603027
Release Date: 1/15/2016
From:
Sent: Monday, November 23, 2015 4:07:16 PM
To:
Cc:
Bcc:
Subject: RE: Rev rul 99-40 attempting to be applied to a credit elect for witholding tax return

We agree that Rev. Rul. 99-40, as it relates to unpaid installments of estimated tax,
does not apply to Form 1042 because filers of such returns are not required to make
estimated payments of income tax.

Please let me know if you have any further questions.

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