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May 16, 2025

IRS Quietly Extends Form 1042 E-Filing Exemption for U.S. Withholding Agents

By Meghan Anderson,Managing Director, TaxLinkedin
Heather Brown,Managing Director, TaxLinkedin
Table of Contents

To the surprise of many tax practitioners, the IRS recently announced an extension to the exemption for domestic withholding agents to file Form 1042 electronically.

According to Notice 2024-26, published in February 2024, domestic and foreign withholding agents were exempt from the requirement to e-file Form 1042, “Annual Withholding Tax Return for U.S. Source Income of Foreign Persons,” for the 2023 tax year, filed in calendar year 2024. This exemption was initially extended to the 2024 tax year for foreign withholding agents only, but it has since been extended to domestic withholding agents as well.

At a conference hosted by the Tax Reporting Group in Arlington, Virginia, on May 6, many tax professionals expressed surprise when Subin Seth of the IRS Office of Associate Chief Counsel (International) mentioned the extension of e-filing relief for domestic withholding agents in tax year 2024.

Seth noted that the IRS had posted an update about the extension on the Form 1042 website in March 2025. However, they did not issue an official Notice, which is their typical procedure for announcing such extensions. As a result, many U.S. withholding agents were unaware that they could have filed a paper Form 1042 for tax year 2024.

Others who have filed an extension to file their Form 1042, pushing the date from March 15 to September 15, should note that they now have the option to file a paper form.

This news comes as a relief for many withholding agents, some of whom had previously reported to the IRS that they faced implementation challenges with e-filing, as noted in Notice 2024-26.

To learn more about Form 1042 or other tax matters, please connect with us.

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