IRS Instruction 945-A – IRS Forms, Instructions, Pubs 2026

IRS Instruction 945-A – IRS Forms, Instructions, Pubs 2026 – Navigating IRS requirements for nonpayroll withholding and certain employment taxes can be complex, but understanding Form 945-A is essential for compliant businesses and tax professionals. The IRS Instructions for Form 945-A (Rev. December 2025) provide clear guidance on reporting federal tax liabilities accurately.

This SEO-optimized guide breaks down everything you need to know about Form 945-A, including who must file, how to complete it, key deadlines, and common pitfalls. Whether you’re filing for backup withholding, pension distributions, gambling winnings, or railroad retirement taxes, this article has you covered.

What Is IRS Form 945-A?

Form 945-A, Annual Record of Federal Tax Liability, is a required attachment for certain annual tax returns. It reports your total federal tax liability by month and day based on when payments were made (look-back period), not when deposits were made or taxes accrued.

Form 945-A is used with:

  • Form 945 — Reports withheld federal income tax from nonpayroll payments (backup withholding, pensions/annuities/IRAs, gambling winnings, Indian gaming profits, voluntary withholding on government payments, etc.).
  • Form CT-1 — Reports railroad retirement taxes (Tier 1 and Tier 2).
  • Form 944 — Reports annual employment taxes for small employers (social security, Medicare, and withheld income tax).

Important: The IRS uses Form 945-A to verify that you deposited taxes on time. Mismatches can trigger an “averaged” failure-to-deposit (FTD) penalty proposal, even if deposits were timely.

Who Must File Form 945-A in 2025–2026?

Not every filer of Forms 945, 944, or CT-1 needs to submit Form 945-A. You must file if you are:

  • A semiweekly schedule depositor, or
  • A monthly schedule depositor who accumulated $100,000 or more in tax liability on any single day during a month (triggering the $100,000 Next-Day Deposit Rule). Once triggered, you remain semiweekly for the rest of the year and the following year.

You generally do NOT need to file Form 945-A if:

  • You are a monthly schedule depositor with no $100,000+ single-day liability, and
  • Your total tax liability for the year is less than $2,500 (small filers on Form 944 may also qualify for reduced deposit requirements).

When and Where To File Form 945-A?

File Form 945-A with your annual return:

  • Form 945 → Due January 31 (or February 10 if deposits were made on time)
  • Form 944 → Due January 31 (or February 10 if deposits timely)
  • Form CT-1 → Due last day of February

File electronically or by mail using the same address as your main return. No separate submission is required—attach it directly.

Step-by-Step Instructions: How To Fill Out Form 945-A?

1. Business Information & Calendar Year

Enter your EIN, business name (exactly as shown on your return), and the calendar year.

2. Identify Your Return Type

The form is one-page and works for all three return types (945, CT-1, 944). Do not complete the monthly summary sections on the main return if you’re attaching Form 945-A.

3. Report Tax Liability by Month (Lines A–L and M)

  • Report liabilities based on the date payments were made (or wages paid), not deposit dates.
  • Enter daily liabilities in the numbered rows under each month (1–31).
  • Subtotal each month on lines A through L.
  • Total for the year goes on line M — this must exactly match the tax amount on your main return:
    • Form 945, line 3
    • Form CT-1, line 15 (or line 19 for prior years)
    • Form 944, line 9

4. Special Adjustments

  • Qualified small business research credit (Form 944 only): Report the credit-elected amount on Form 944, line 8, and adjust daily liabilities accordingly.
  • Prior-period adjustments: Do not include on Form 945-A — report on Form 945-X, 944-X, or CT-1 X instead.

5. Examples from IRS Instructions

Example 1 (Backup Withholding + Gambling Winnings): A semiweekly depositor withholds on the 15th of each month plus an extra backup withholding on December 24 → Report on line 15 each month and line 24 for December.

Example 2 (Pension Distributions): $52,000 withheld January 6 and $35,000 January 20 → Enter on January lines 6 and 20.

Example 3 (Monthly Depositor Hits $100,000 Threshold): A monthly depositor accumulates $101,000 on January 20 → Becomes semiweekly and must complete Form 945-A for the full year.

Common Mistakes To Avoid

  • Reporting on the wrong day (use payment date, not deposit date)
  • Including prior-period adjustments
  • Line M not matching the main return total
  • Monthly depositors forgetting to switch to semiweekly after hitting $100,000

Penalties for Errors or Late Deposits

The IRS can propose an averaged FTD penalty if Form 945-A is missing or incorrect. Correct previously reported liabilities by filing an amended Form 945-A (if assessed an FTD penalty) or the appropriate adjusted return (945-X, etc.).

Download the Latest Forms & Instructions

Final Thoughts

Form 945-A is a simple but critical form for semiweekly depositors and those who cross the $100,000 threshold. Keeping accurate daily records throughout the year makes completion straightforward and helps avoid costly deposit penalties.

Always check IRS.gov for any post-publication updates, especially if legislation affects nonpayroll withholding or employment taxes. For personalized advice, consult a qualified tax professional.

Last updated based on IRS guidance as of February 2026.