At the end of 2021, the IRS released new federal tax withholding election Form W-4P (for periodic payments) and Form W-4R (for nonperiodic payments and eligible rollover distributions) for use in 2022. At that time, the IRS also announced that the 2021 version of Form W-4P could continue to be used through the end of 2022, to give retirement systems more time to implement the new withholding process for new payees and other payees who complete a 2022 Form W-4P or Form W-4R. For more detail on these changes, see our January 21, 2022 E-Alert: IRS Finalizes 2022 Federal Tax Withholding Guidance and Forms.

As we reach the halfway point of 2022, it is a good time for retirement systems to be sure that they are on track to implement the new federal tax withholding election forms no later than January 1, 2023. We do not expect that the IRS will provide any additional delay for using the new forms, so retirement systems should be working toward testing and implementation of the new system.

As we have worked with many of our clients through this process, we recognize the importance of having a plan in place to make all necessary decisions, as well as providing appropriate staff training. Please contact Robert L. Gauss, Audra Ferguson-Allen, Lisa Harrison, Lindsay Knowles, or the Ice Miller Workplace Solutions lawyer with whom you work for more information.

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