Short Summary: FAQ: Is the payroll tax deferral voluntary for the employer or employee?

The notice implies that the employer is responsible for the deferred taxes but provides that the deferred taxes are to be withheld from employees beginning in January. [...] The notice goes on to state, “If necessary, the [employer] may make arrangements to otherwise collect the total Applicable Taxes from the employee.” But the notice provides no further guidance as to what this might mean. [...] It also provides no guidance on what happens if the person is no longer an employee and the employer is unable to collect the unpaid taxes. [...] Must an employer decide by September 1 whether to defer withholding or not? The notice is silent on whether an employer must defer the withholding for the entire deferral period (September 1 to December 31) or whether an employer can start deferring at any point during the deferral period. [...] Can an employer continue to withhold the tax, but suspend depositing it with the Treasury? No, the notice indicates that the deposit obligation is linked to when the tax is withheld.