The Section 1441 Compliance Program

Tax Department
Lewis J. Greenwald, David H. Kaplan
February 2006

On September 29, 2004, the IRS announced the establishment of the Section 1441 Voluntary Compliance Program (the "Section 1441 VCP") for U.S. withholding agents that may not be in full compliance with their Code Sections 1441 and 1442 withholding obligations. The Section 1441 VCP was scheduled to expire on December 31, 2005; however, due to the popularity of the program, the IRS extended the program through March 31, 2006.

Client Advisory (PDF)