Background:
An internal memo of the Federal Inland Revenue Service (FIRS)
dated July 25 1 2018 and captioned "Re: Circular on
Withholding Tax Utilisation and K-Card Update Key
Deliverables" (Memo) has become public knowledge. The Memo
directed all Tax Controllers and State Monitors to issue to
taxpayers, a letter in a template captioned
"Overpayments/Withholding Tax Confirmation/Reconciliation for
System Upload" (WHT Reconciliation Notice). Each WHT
Reconciliation Notice is to be accompanied by a withholding tax
(WHT) usage request sheet (Request Sheet). On receipt of the WHT
Reconciliation Notice, the taxpayer is to complete the Request
Sheet and go to its relevant FIRS office for a review,
reconciliation and sign-off, by the taxpayer and the FIRS, of both
the Request Sheet and a journal adjustment voucher (JAV). While the
Memo required that that the sign-off of the Request Sheet and JAV
be completed by August 30, 2018, the WHT Reconciliation Notice
gives the
