Information Return Intelligence

Jason Dinesen

Your weekly briefing on 1099s, 1042-S, and everything related to information forms.

  1. -6 дн.

    Episode 45: Want to Use IRIS? Start the Process Now

    FIRE is going away. If you haven't figured out what you're doing next, now is the time. In the latest episode of Information Return Intelligence, Jason Dinesen looks ahead to the end of the FIRE system and explains why businesses shouldn't wait until January to make the move to IRIS—or to find a third-party filing provider. For organizations planning to file directly through IRIS, getting started involves more than simply creating an account. You'll need to determine whether you're using the Taxpayer Portal or the Application-to-Application (A2A) system, apply for the appropriate Transmitter Control Code (TCC), and potentially complete testing before you're ready to file. And don't assume your old FIRE credentials will carry over: a FIRE TCC won't work with IRIS. Planning to use a vendor instead? There's still work to do. Vendor onboarding, system setup, data preparation, and the inevitable learning curve all take time—especially for organizations filing larger volumes of information returns. The filing season may still seem months away, but that's exactly why now is the time to get started. In this episode: Why the November shutdown of FIRE matters nowThe Taxpayer Portal vs. A2A options within IRISWhy FIRE TCCs don't transfer to IRISThe potential 45-day wait for a new TCCA2A testing requirementsThe 250-record CSV limit in the Taxpayer PortalWhy vendor onboarding shouldn't wait until JanuaryThe case for outsourcing your information-return filingWhether you're planning to handle IRIS yourself or rely on a vendor, the message is simple: don't make this a January project. Information Return Intelligence is powered by IOFM and produced by Dinesen Media Ventures.

  2. 8 сент.

    Episode 44: Form 1099-K Part 3

    This week on Information Return Intelligence, we wrap up our three-part series on Form 1099-K by tackling a common question: Why not just issue a Form 1099-NEC and avoid all the complexity? The answer is simple: because the regulations say not to. Here are the other parts:  Part 1 Part 2 When 1099-K Takes Priority Suppose you pay a contractor $1,000 by check or ACH in April and another $1,000 through a payment app in July. If the July payment is made in a way that transfers the reporting obligation to the payment app, you are responsible only for the $1,000 April payment for purposes of Form 1099-NEC. That creates an interesting result. You paid the contractor $2,000 during the year, and your books may show $2,000 of contract labor expense. But because only $1,000 is subject to reporting by you, you would not issue a Form 1099-NEC under the $2,000 reporting threshold applicable for 2026. This is why businesses need systems capable of distinguishing between payments potentially reportable on Form 1099-NEC and payments potentially reportable on Form 1099-K. Why Not Report Everything Yourself? A common response is: Why bother sorting through all of this? Why not simply report the entire $2,000 on Form 1099-NEC? The regulations under Sections 6041 and 6041A provide that transactions subject to both those reporting provisions and the Form 1099-K rules of Section 6050W are reported under Section 6050W — not under the Form 1099-MISC or 1099-NEC rules. This is different from the familiar corporate exception. Generally, you aren't required to issue a Form 1099 to a corporation, although there are exceptions such as certain legal and medical payments. But the corporate exception generally does not prohibit you from voluntarily issuing a Form 1099. The Form 1099-K rules are different. If a transaction could be subject to Form 1099-K reporting, the regulations direct the transaction into the Section 6050W reporting regime rather than the Form 1099-MISC or 1099-NEC regime. What If No 1099-K Is Actually Issued? That doesn't necessarily change your responsibility. Certain third-party settlement organizations may not actually issue a Form 1099-K because the payee doesn't meet the applicable transaction and dollar thresholds. But the regulations tell the payer to disregard those thresholds when determining whether the payment should instead be reported on Form 1099-NEC or Form 1099-MISC. In other words, the fact that the contractor ultimately doesn't receive a Form 1099-K doesn't automatically mean you should issue a Form 1099-NEC instead. The Practical Takeaway Businesses can't solve the complexity of Form 1099-K by simply saying, "We'll issue a 1099-NEC for everything." Instead, you need to know how each payment was made and who has the reporting obligation. That becomes especially important when the same contractor is paid in multiple ways during the year — perhaps by ACH, credit card, PayPal, Venmo, or another payment method. The amount you ultimately report on Form 1099-NEC could be very different from the contractor's total payments for the year. One way to make this easier is to consolidate payment methods whenever possible. The fewer ways you pay contractors, the easier it becomes to track transactions and determine who is responsible for information reporting. Listen to the full episode of Information Return Intelligence for the details and examples.

  3. 1 сент.

    Episode 43: FIRE, Extinguished

    The IRS has announced the official shutdown date for the Filing Information Returns Electronically (FIRE) system: 3:00 p.m. Eastern Time on November 19, 2026. We knew this day was coming. Now we know exactly when — right down to the hour. A Little FIRE History FIRE has been around since 1986 and, for most of its existence, was the primary IRS intake system for electronically filed information returns, including Forms 1099 and 1042-S. That began to change with the introduction of the Information Returns Intake System (IRIS). IRIS debuted in 2023 for filing 2022 information returns. Initially, IRIS had limitations. For example, Form 1042-S wasn't available through the system during its first few years. That meant FIRE and IRIS needed to coexist. But the IRS made it clear that this wouldn't last forever. In May 2025, the IRS announced that FIRE would be retired at the end of 2026. Throughout 2026, IRS guidance continued to reinforce that timeline. Now we have the official shutdown: November 19 at 3:00 p.m. Eastern. That means IRIS will be the IRS filing system available for 2026 information returns filed in 2027. What Should FIRE Users Do? If you're currently filing through FIRE, you essentially have two choices. Option 1: Use a third-party vendor. There are numerous information return filing vendors that connect to IRIS. Instead of interacting directly with the IRS system, you provide your information to the vendor and the vendor handles transmission to the IRS. If this is the route you're taking, don't wait until January to start looking for a vendor. Larger filers in particular may face onboarding and other implementation requirements. Waiting until filing season could leave too little time to get everything in place. Even smaller filers should start exploring their options now. Unexpected hurdles have a way of appearing at the worst possible time. Option 2: File directly through IRIS. If you've always been a do-it-yourself FIRE filer, you can continue doing things yourself through IRIS. But you can't simply take your existing FIRE credentials and move them over. A FIRE Transmitter Control Code (TCC) does not work in IRIS. You'll need to apply for an IRIS TCC, and the process can take up to 45 days. You should also make sure you can successfully access the system. Login issues are one of the most common complaints I hear about IRIS. Depending on how you intend to file, additional setup may also be required. For example, IRIS Application-to-Application (A2A) filing requires testing before you can begin transmitting production files. Don't Make This a January Project As this episode drops, we're still several months away from filing season. It might seem like there's plenty of time. But whether you're moving to a third-party vendor or planning to use IRIS yourself, there may be more involved in the transition than you expect. The takeaway: If you're still using FIRE, start planning your transition now. FIRE has been around for 40 years. At 3:00 p.m. Eastern on November 19, that era officially comes to an end.

  4. 25 авг.

    Episode 42: Substitute Forms, A Bigger 1099 Deal than You'd Think

    The IRS has released Revenue Procedure 2026-18, its annual guidance on substitute forms — and despite the somewhat obscure name, the rules can affect virtually anyone responsible for filing or furnishing Forms 1099. What Is a Substitute Form? A substitute form is an information return produced in a format other than the official form supplied by the IRS. The IRS publishes detailed specifications governing how these forms must look and what information they must contain. For organizations that e-file their information returns with the IRS, this generally isn't something to worry about on the filing side. Whether you're filing directly through IRIS or using third-party software, the electronic filing process takes care of the IRS filing specifications. Paper filing is different. You generally cannot download Copy A of a Form 1099 from the IRS website, print it on ordinary paper, and mail it to the IRS. Paper filings must meet the IRS's specifications, which is why organizations that still file on paper typically use the special forms available from office-supply stores or other forms providers. But substitute-form rules don't stop with the IRS copy. Recipient Copies Count, Too The rules also apply to the statements furnished to recipients. That means organizations need to pay attention to the format of the Forms 1099 they provide to contractors, vendors, and other recipients — whether those statements are furnished on paper or electronically. If you prepare returns directly through IRIS and download the recipient PDF generated by the system, you're fine using that version. But in general, you can't simply put the relevant information on a piece of paper and call it a Form 1099. Recipient statements must meet IRS requirements. A Change to Address Fields Revenue Procedure 2026-18 highlights a change that has also appeared on some of the newer Forms 1099: address information is being separated into individual fields rather than appearing in one large address box. City, state, ZIP code, and other components now have their own fields. When these changes first appeared on forms such as the 2026 Forms 1099-NEC and 1099-MISC, they looked largely cosmetic. Their inclusion in the substitute-form revenue procedure suggests there may be more to the change, potentially including implications for IRIS, although the IRS has not provided enough information yet to say definitively. Welcome to the Information Return Family Revenue Procedure 2026-18 also identifies several additions to the information-return lineup: Form 1098-VLI, for reporting certain qualified passenger vehicle loan interest.Form 1099-LPS, relating to long-term care premiums paid.Form 5498-TA, relating to Trump account contributions.Form 1099-DA, for digital asset reporting. Although Form 1099-DA first came into use for 2025 reporting, the IRS continues to list it among the new forms in this revenue procedure.Meanwhile, one form has officially been put out to pasture: Form 1098-MA. The form related to the Hardest Hit Fund, Short Refinance, and Making Home Affordable programs. With funding for those programs expired, the form has been retired as well. The Takeaway If you e-file your Forms 1099 with the IRS, the substitute-form rules generally aren't something you need to think about when transmitting the returns to the government. But if you paper file with the IRS, the rules matter. And regardless of how you file with the IRS, they also matter when you furnish statements to recipients. Revenue Procedure 2026-18 gets deep into technical specifications that most organizations will never need to study line by line. But the broader lesson applies to everyone: a Form 1099 isn't simply a collection of numbers and names. The format matters, too. Listen to this week's Information Return Intelligence, powered by IOFM, for more on Revenue Procedure 2026-18 and what the substitute-form rules mean for information return filers.

  5. 11 авг.

    Episode 40: IRS Releases FAQs on Overtime, With One 1099 Item

    The IRS recently released new FAQs dealing with the deduction for qualified overtime compensation. At first glance, this would seem to have nothing to do with 1099s. Overtime is generally an employee issue, which means W-2 reporting. But buried in the FAQs is an interesting question: When would qualified overtime compensation be reported on Form 1099-MISC or 1099-NEC instead of Form W-2? Yes, that can happen. The issue comes down to worker classification. The Department of Labor and the IRS use different tests for determining whether a worker is an employee or an independent contractor. That means it is possible for someone to be treated as an employee for purposes of the Fair Labor Standards Act — and therefore entitled to overtime — while still being treated as an independent contractor for federal tax purposes. Section 530 relief can add another wrinkle. A business may be permitted to continue treating certain workers as independent contractors for federal tax purposes even when their underlying classification might otherwise point toward employee status. In this episode of Information Return Intelligence, we look at this unusual overlap between overtime rules and 1099 reporting, including: Why DOL and IRS worker-classification rules don't always produce the same answerWhen overtime could potentially appear on a 1099How Section 530 relief can complicate the analysisWhy businesses should review contractor classifications rather than assuming "contractor" means the same thing for every federal lawIt's another example of why worker classification — and 1099 reporting — isn't always as straightforward as it looks. Information Return Intelligence is powered by IOFM.

  6. 4 авг.

    Episode 39: Settlement Payments, Attorney Fees and 1099 Reporting

    If your organization pays a legal settlement, and part of that settlement goes directly to the plaintiff's attorney, should that attorney portion be included on the plaintiff's Form 1099-MISC? The answer is yes. In this week's episode of Information Return Intelligence, Jason reviews the recent Eiler v. Commissioner decision, which reinforces a long-standing principle of tax law: the plaintiff is generally taxed on the entire taxable settlement, including amounts paid directly to their attorney. The episode explains: Why most taxable settlements are reported in Box 3 of Form 1099-MISCThe limited situations where settlement proceeds are not taxable (such as certain physical injury damages and replacement of capital)How the doctrine of constructive receipt causes attorney fees to remain taxable to the plaintiff, even when they never physically receive the moneyWhy the taxpayers in Eiler were required to report the full $64,750 settlement even though they kept only about $4,700How the earlier Sinyard v. Commissioner case continues to support this reporting positionWhy the taxpayers were also denied a deduction for their attorney fees after unsuccessfully arguing that their case involved civil rights violationsAlthough the decision doesn't establish any new legal precedent, it serves as a timely reminder for accounts payable and information reporting professionals: when a settlement is taxable, the amount reported on Form 1099-MISC generally includes the full taxable settlement—even if the settlement agreement directs part of the payment to the recipient's attorney.

  7. 28 июл.

    Episode 38: Correction Deadline Approaching to Avoid Penalties

    Every year, there's a little-known deadline that can save 1099 filers from costly IRS penalties. In this episode of Information Return Intelligence, Jason explains why August 3, 2026 (normally August 1) is such an important date for correcting information returns.  Learn how the IRS treats errors on timely filed forms, how many corrections you can make without penalty, and which mistakes don't require correction at all. Jason also discusses the de minimis error rules, why intentional disregard can dramatically increase penalties, and why it's still important to file corrections even after the August deadline has passed.  The episode also covers an emerging issue for organizations that filed through FIRE this year and may need to submit corrections after the system is retired at the end of 2026.  Topics include:   The August 3 correction deadline for 2026  The "greater of 10 or 0.5%" penalty relief rule  De minimis dollar amount exceptions  Errors that do—and do not—require correction  How IRS computer matching affects correction requirements  Why intentional disregard penalties are so severe  Filing corrections through the same system as the original return  What FIRE users should watch for as the transition to IRIS continues  Whether you filed six Forms 1099 or sixty thousand, this episode will help you understand when corrections matter—and how to minimize your penalty exposure before time runs out.

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Your weekly briefing on 1099s, 1042-S, and everything related to information forms.