IRS Form W-2AS Guide: American Samoa Wage and Tax Statement

Introduction: What Is IRS Form W-2AS?

IRS Form W-2AS, officially titled American Samoa Wage and Tax Statement, is a specialized federal and territorial employment tax return. Governed jointly by the Department of the Treasury through the Internal Revenue Service (IRS), the Social Security Administration (SSA), and the American Samoa Government Department of Treasury, this form is the territorial counterpart to the standard Form W-2.

American Samoa maintains an independent tax system that operates separately from the standard internal revenue laws of the 50 U.S. states. However, because American Samoan workers participate fully in the federal Social Security and Medicare programs, employers must report payroll information using a form that accommodates both territorial and federal tax rules.

Form W-2AS serves as the annual reconciliation document for employers in American Samoa. It reports taxable wages paid for work performed in the territory, the amount of local American Samoa income tax withheld, and the mandatory contributions made toward federal Social Security and Medicare trust funds.

Purpose of the Form: Why Does Form W-2AS Exist?

Unlike residents of the mainland United States who pay federal income tax directly to the IRS, residents of American Samoa pay income tax directly to the local territorial government. Consequently, local employers do not withhold federal income tax from wages earned within the territory; instead, they withhold American Samoa income tax.

Despite this tax distinction, American Samoan employees are covered under the Federal Insurance Contributions Act (FICA). This means that every eligible worker pays the same federal Social Security and Medicare tax rates as workers in the mainland United States.

Form W-2AS bridges these two distinct tax authorities. It provides the American Samoa Tax Office with the local wage data needed to process territorial income tax returns, while simultaneously supplying the Social Security Administration with the federal wage history needed to calculate workers’ future retirement, disability, and Medicare benefits.

Who Needs to File Form W-2AS?

Form W-2AS involves legal responsibilities for both territorial employers and local employees:

• American Samoa Employers: Any commercial business, sole proprietorship, corporation, partnership, or government agency that pays wages or compensation for services performed by an employee in American Samoa must prepare and file Form W-2AS.
• Employers Withholding FICA or Local Taxes: Employers who paid wages subject to American Samoa income tax withholding or federal Social Security and Medicare taxes must submit the form, even if the worker earned less than standard reporting thresholds.
• Territorial Employees: Workers do not prepare the form themselves; rather, they receive Copies B and C from their employers and use the reported figures to file their annual American Samoa territorial income tax returns.

Who Is Exempt or Not Required to File?

Many businesses and workers operating outside American Samoa or outside formal employment relationships do not use Form W-2AS:

• Employers in the 50 States or Other Territories: Employers in mainland states use standard Form W-2. Employers in other U.S. territories use their respective localized variants: Guam uses Form W-2GU, the U.S. Virgin Islands uses Form W-2VI, and the Northern Mariana Islands uses Form W-2CM.
• Independent Contractors and Freelancers: Independent contractors operating in American Samoa do not receive Form W-2AS; their non-employee compensation is reported on Form 1099-MISC or local territorial equivalents.
• Self-Employed Individuals: Sole proprietors and business partners without employees report their self-employment earnings using Form 1040-SS rather than Form W-2AS.
• Volunteers: Unpaid volunteers and interns receiving no taxable wages or taxable living allowances are exempt.

When to File: Deadlines and Frequency

Form W-2AS is an annual tax statement with a single universal deadline shared across all reporting authorities:

• January 31 Distribution Deadline: Employers must furnish Copies B and C of Form W-2AS to their employees no later than January 31 of the year following the tax year.
• January 31 Government Filing Deadline: Employers must file Copy A (along with transmittal Form W-3SS) with the Social Security Administration by January 31, whether filing electronically or on paper.
• January 31 Territorial Filing Deadline: Employers must also submit Copy 1 to the American Samoa Government Department of Treasury, Tax Office, by January 31.

If January 31 falls on a Saturday, Sunday, or legal holiday, the deadline moves to the next business day.

Where and How to File Form W-2AS

Filing Form W-2AS requires distributing distinct copies across federal, territorial, and personal channels:

Submitting Copy A to the Social Security Administration: Employers submit Copy A, accompanied by transmittal Form W-3SS, directly to the Social Security Administration. Employers can submit electronically using the SSA’s Business Services Online (BSO) portal. Any employer filing 10 or more informational returns must file electronically under federal law.

Submitting Copy 1 to the American Samoa Tax Office: Copy 1 of Form W-2AS must be submitted directly to the American Samoa Tax Office in Pago Pago in accordance with local filing procedures.

Furnishing Copies B and C to Employees: Employers deliver Copy B (to be attached to the employee’s territorial tax return) and Copy C (for the employee’s personal files) by hand or mail. Electronic delivery is permitted only if the worker has provided affirmative, informed electronic consent.

Paper SSA Mailing Address: If permitted to file paper forms, employers send scannable Copy A sheets and Form W-3SS to the official Social Security Administration address as per instructions (or the official IRS address as per instructions if directed).

Step-by-Step Instructions to Fill Out Form W-2AS

Form W-2AS features lettered boxes for identifying information and numbered boxes for territorial and federal wage reporting.

Box	Title / Description	Required Information & Operational Rule
Box a	Employee’s Social Security Number	Enter the employee’s nine-digit SSN exactly as printed on their official Social Security card.
Box b	Employer Identification Number (EIN)	Enter the employer’s nine-digit federal EIN assigned by the IRS (formatted as XX-XXXXXXX).
Box c	Employer’s Name, Address, & ZIP	Enter the legal business name and physical or mailing address in American Samoa.
Box d	Control Number	An optional internal payroll identification number used by the employer.
Boxes e–f	Employee’s Legal Name & Address	Enter the worker’s legal first name, middle initial, last name, and complete residential address.
Box 1	Wages, Tips, Other Compensation	Total taxable compensation subject to American Samoa territorial income tax.
Box 2	American Samoa Income Tax Withheld	Total territorial income tax withheld from employee paychecks throughout the calendar year.
Box 3	Social Security Wages	Total wages subject to federal Social Security tax, capped at the annual federal statutory limit.
Box 4	Social Security Tax Withheld	Total federal Social Security tax withheld (6.2% of the wages reported in Box 3).
Box 5	Medicare Wages and Tips	Total wages subject to federal Medicare tax (not subject to any annual wage cap).
Box 6	Medicare Tax Withheld	Total federal Medicare tax withheld (1.45% of Box 5, plus 0.9% Additional Medicare Tax if applicable).
Boxes 7–8	Social Security & Allocated Tips	Report employee-reported tips subject to Social Security and any allocated tips.
Box 10	Dependent Care Benefits	Total pretax dependent care benefits provided under an employer assistance program.
Box 11	Nonqualified Plans	Distributions made from a nonqualified deferred compensation plan.
Box 12	Coded Benefit Items	Enter standard IRS letter codes (e.g., Code D for 401(k) deferrals, Code W for HSA contributions).
Box 13	Checkboxes	Check if applicable: Statutory Employee, Retirement Plan participant, or Third-Party Sick Pay.
Box 14	Other Information	Used for optional or local employer reporting, such as local wage deductions or union dues.

Understanding Key Boxes on Form W-2AS

Box 1 vs. Box 2: Local Income Tax. Unlike mainland W-2 forms that report federal income tax in Box 2, Form W-2AS reports American Samoa income tax withheld. Box 1 reflects the employee’s total gross taxable wages subject to American Samoa territorial tax rates.

Boxes 3 through 6: Federal FICA Taxes. Boxes 3, 4, 5, and 6 function identically to standard federal W-2 forms. Box 3 captures Social Security wages up to the annual national wage ceiling, while Box 5 captures all Medicare wages without a ceiling. Boxes 4 and 6 reflect the standard 6.2% and 1.45% tax withholdings remitted to the federal government.

Box 12 Reporting Codes. Employers must use standard federal letter codes in Box 12. For instance, elective deferrals to a 401(k) plan are reported under Code D, while the cost of employer-sponsored health coverage is reported under Code DD for informational tracking.

Required Documents and Information Needed Before Filling

Before preparing Form W-2AS, employers should assemble the following payroll and tax records:

• Employee Withholding Certificates: Completed withholding forms indicating employee marital status, dependents, and territorial withholding allowances.
• Employee Identity Verification: Verified Social Security cards and legal name records for all active personnel.
• Year-End Payroll Summaries: Detailed payroll journals showing gross compensation, pretax deductions, local tax withholdings, and FICA deductions.
• Official Account Numbers: The business’s federal Employer Identification Number (EIN) and American Samoa territorial tax account number.
• Benefit Plan Reports: Contribution summaries from retirement plan administrators and health insurance providers.

Common Mistakes to Avoid

Errors on Form W-2AS can disrupt tax processing in both Pago Pago and Washington, D.C. Watch out for these frequent mistakes:

• Using Standard Form W-2: Submitting a mainland Form W-2 instead of Form W-2AS causes severe errors because the IRS system will mistakenly treat territorial withholding as federal income tax withholding.
• Failing to Send Copy 1 to the Local Tax Office: Sending Copy A to the SSA while forgetting to submit Copy 1 to the American Samoa Tax Office prevents local authorities from verifying employee tax returns.
• Mismatched Employee Names and SSNs: Entering nicknames or incorrect digits causes the Social Security Administration to reject wage records, depriving employees of retirement credits.
• Missing the January 31 Deadline: Late distribution to workers or late filing with the government triggers automatic information return penalties.
• Truncating SSNs on Government Copies: While some jurisdictions permit truncating employee Social Security Numbers on employee copies, Copy A sent to the SSA must display the complete nine-digit number.

Penalties for Non-Filing or Errors

Failing to prepare and submit Form W-2AS accurately exposes employers to dual-jurisdiction penalties:

• Federal Information Return Penalties (IRC Section 6721 & 6722): The IRS assesses penalties for late, incomplete, or incorrect filings sent to the SSA or furnished to employees:
  • Approximately $60 per form if filed within 30 days late.
  • Approximately $130 per form if filed between 31 days late and August 1.
  • Approximately $330 per form if filed after August 1 or not filed at all.
  • A minimum of $660 per form (with no maximum cap) for intentional disregard.
• American Samoa Territorial Penalties: The American Samoa Tax Office imposes separate local penalties, interest charges, and potential business license suspensions for failing to file Copy 1 or underreporting local wage withholdings.

Related Forms and Schedules

Form W-2AS operates within a specialized network of territorial and federal tax forms:

• Form W-3SS: Transmittal of Wage and Tax Statements (the summary transmittal sheet that must accompany paper Copy A filings to the SSA).
• Form W-2c: Corrected Wage and Tax Statement (used to fix errors on previously filed W-2AS forms).
• Form W-3c: Transmittal of Corrected Wage and Tax Statements.
• Form 941-SS: Employer’s Quarterly Federal Tax Return for American Samoa, Guam, the Northern Mariana Islands, and the U.S. Virgin Islands (used to remit FICA taxes quarterly).
• Form 1040-SS: U.S. Self-Employment Tax Return for residents of American Samoa and other territories.
• Form W-2GU / Form W-2VI: Counterpart wage statements for Guam and the U.S. Virgin Islands.

Frequently Asked Questions (FAQs)

How does Form W-2AS differ from standard Form W-2?

Standard Form W-2 reports federal income tax withheld in Box 2 for workers in the 50 states. Form W-2AS is tailored for American Samoa, reporting local American Samoa income tax withheld in Box 2, while retaining standard federal reporting for Social Security and Medicare in Boxes 3 through 6.

Where do employers submit Copy A of Form W-2AS?

Copy A of Form W-2AS must be filed directly with the Social Security Administration, not the IRS. Employers can file Copy A electronically via the SSA’s Business Services Online (BSO) portal or mail paper scannable sheets along with Form W-3SS.

Do American Samoa residents pay federal income taxes on W-2AS wages?

Generally, no. Wages earned in American Samoa by bona fide territorial residents are subject to American Samoa territorial income tax rather than U.S. federal income tax. However, workers remain fully subject to federal Social Security and Medicare taxes.

What transmittal form must accompany paper Form W-2AS filings?

When filing paper copies with the Social Security Administration, employers must attach Form W-3SS, Transmittal of Wage and Tax Statements. Standard Form W-3 cannot be used for territorial returns.

Can employers in American Samoa file Form W-2AS electronically?

Yes. Employers can register for the Social Security Administration’s Business Services Online (BSO) portal to upload and submit Form W-2AS wage files electronically, which satisfies federal filing requirements.

How does an employer correct a mistake on a filed Form W-2AS?

To correct an error after filing, the employer must prepare Form W-2c (Corrected Wage and Tax Statement), furnish copies to the employee, and send Form W-2c with transmittal Form W-3c to the Social Security Administration and the American Samoa Tax Office.

Conclusion: Key Takeaways

IRS Form W-2AS, American Samoa Wage and Tax Statement, is a vital administrative document connecting territorial payroll with federal social insurance programs. It ensures that workers in American Samoa fulfill their local tax obligations while earning credit toward federal Social Security retirement and Medicare benefits.

For employers in American Samoa, compliance requires separating local income tax withholding from federal FICA calculations and meeting the January 31 deadline across all three key parties: employees, the Social Security Administration, and the local American Samoa Tax Office. Maintaining accurate payroll records and using the proper territorial forms ensures a smooth filing season and protects both the business and its workforce.