Missing Participant

[Randy Watson]

Are you required to withhold taxes prior to escheating amounts to a state's unclaimed property fund? If so, what if you don't have a valid SSN?

[Guest Kabert]

I never have.

Also, I recall a colleague once telling me she did, but then afterwards discovering that that the IRS didn't think withholding applied (and wondering how or whether to unwind the withholding). I think I remember seeing some unofficial IRS guidance on this question -- perhaps in the form of one of those ABA or ASPPA Q&As to the agencies.