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Issue Number: 2020–03 | January 14, 2020

Reminders for Tax Year 2019 Form Series 1099 Reporting

Regulatory Deadlines

We would like to remind payers of approaching regulatory deadlines with respect to Form series 1099 reporting for tax year 2019.

Generally, the deadlines for filing forms with the Internal Revenue Service (“IRS”) are February 28, if paper filed, or March 31, if electronically filed, while the deadline for furnishing recipient copies is January 31. However, it is important to remember that the Form 1099-MISC reporting including Box 7 Non-Employee Compensation (“NEC”) payments deadline is January 31 for both filing with the IRS (either via paper or E-File) as well as for furnishing statements to recipients. Also, the IRS no longer offers automatic 30-day extensions for Form 1099-MISC NEC reporting. Any extension request would require showing cause – e.g., a catastrophic event, fire, casualty, or natural disaster, etc.

The below table details the upcoming deadlines.

Form Type Paper File Deadline to IRS E-File Deadline to IRS Extension Request to IRS (Paper file) Extended deadline (Paper file) Extension Request to IRS
(E-file)
Extended deadline (E-file) Recipient Statement Deadline
1099-MISC, with NEC January 31, 2020 January 31, 2020 January 31, 2020
(not automatic)
N/A January 31, 2020
(not automatic)
N/A January 31, 2020
1099-MISC, without NEC February 28, 2020 March 31, 2020 February 28, 2020 March 30, 2020 March 31, 2020 April 30, 2020 January 31, 2020
1099-MISC, reporting substitute payments or gross proceeds to attorneys February 28, 2020 March 31, 2020 February 28, 2020 March 30, 2020 March 31, 2020 April 30, 2020 February 18*, 2020
1099-DIV February 28, 2020 March 31, 2020 February 28, 2020 March 30, 2020 March 31, 2020 April 30, 2020 January 31, 2020
1099-INT February 28, 2020 March 31, 2020 February 28, 2020 March 30, 2020 March 31, 2020 April 30, 2020 January 31, 2020
1099-B February 28, 2020 March 31, 2020 February 28, 2020 March 30, 2020 March 31, 2020 April 30, 2020 February 18*, 2020
1099-C February 28, 2020 March 31, 2020 February 28, 2020 March 30, 2020 March 31, 2020 April 30, 2020 January 31, 2020
1099-K February 28, 2020 March 31, 2020 February 28, 2020 March 30, 2020 March 31, 2020 April 30, 2020 January 31, 2020
1099-OID February 28, 2020 March 31, 2020 February 28, 2020 March 30, 2020 March 31, 2020 April 30, 2020 January 31, 2020
1098-F January 31, 2020 January 31, 2020 February 28, 2020 March 2, 2020 March 31, 2020 April 30, 2020 January 31, 2020
1099-LS February 28, 2020 March 31, 2020 February 28, 2020 March 30, 2020 March 31, 2020 April 30, 2020 February 28, 2020
1099-SB February 28, 2020 March 31, 2020 February 28, 2020 March 30, 2020 March 31, 2020 April 30, 2020 February 28, 2020

—The February 18, 2020 deadline is adjusted to reflect that in 2020 the original due date of February 15, 2020 is a Saturday, and the following Monday (February 17, 2020) is a federal holiday (Martin Luther King, Jr. Day).

Extensions:

Form series 1099 extensions are available via the Form 8809 (found here). The extension request must be submitted to the IRS on or before the applicable reporting deadline. The Form 8809 generally allows for payers to receive an automatic 30-day extension to file with the exception of Form 1099-MISC NEC reporting. Importantly, the 30-day extension does not apply to the payment of tax due or furnishing recipient copies.

To request an extension for recipient copies, payers must send a letter or fax to the IRS with (a) payer name, (b) payer TIN, (c) payer address, (d) type of return, (e) a statement that extension request is for providing statements to recipients, (f) reason for delay, and (g) the signature of the payer or authorized agent. This extension request must be postmarked by the date that statements are due to recipients and should be addressed or faxed to:

Internal Revenue Service
Attn: Extension of Time Coordinator
240 Murall Drive Mall Stop 4360
Kearneysville, WV 25430
Fax: 877-477-0572 or 304-579-4015

If the request is approved, payers will have 30 extra days to furnish recipient copies.

KPMG Reminders and Observations:

To the extent payers are reporting Form 1099-MISC with NEC and without NEC, KPMG urges these payers to report these in separate transmissions to avoid inadvertent late penalties under section 6721.

As always, when sending anything to the IRS in paper, we would encourage you to send this via certified mail, return receipt required in order to have documentation of timely filing.

Changes for Tax Year 2019

While most Form series 1099 remain unchanged from the prior 2018 tax year, there are a few updates applicable for tax year 2019 of which payers should be mindful. Specifically, changes and additions for this year include:

—Form 1099-B: Box 3 is now a checkbox for reporting a disposition of a Qualified Opportunity Fund (QOF) investment or collectibles proceeds. Information that was previously reported in Box 3 is now contained in Box 12 of the form.
—New Forms: Forms 1098-F, 1099-LS, and Form 1099-SB are new forms for tax year 2019 relating to income associated with the following types of transactions:
–Form 1098-F, Fines, Penalties, and Other amounts
–Form 1099-LS, Reportable Life Insurance Sales
–Form 1099-SB, Seller’s Investment in Life Insurance Contract

 KPMG Reminders and Observations:

The scope of reportable policy sales and death benefits reportable for Forms 1099-LS and 1099-SB are clearly defined by those final 6050Y regulations released on October 25, 2019. Section 6050Y (a) requires reporting on payments made by an acquirer in a reportable life insurance policy sale on Form 1099-LS, Reportable Life Insurance Sales. A reportable policy sale is defined under 6050Y (a) as the acquisition of an interest in a life insurance contract where the acquirer has no substantial family, business, or financial relationship with the insured apart from the acquirer’s interest in such life insurance contract. Section 6050Y(b) requires the policy issuer to report certain information to the seller on Form 1099-SB, Seller’s Investment in Life Insurance Contract.

Additionally, it is worth noting that section 6050Y(c) requires payers to report payments of reportable death benefits on Form 1099-R, Distributions From Pensions, Annuities, Retirement or Profit-Sharing Plans, IRAs, Insurance Contracts, etc. The term reportable death benefits means amounts paid by reason of the death of the insured under a life insurance contract that has been transferred in a reportable policy sale. The regulations provide that the amounts must be attributable to an interest in the life insurance contract that was transferred in a reportable policy sale.

For Your Reference:

The text of 2019 General Instructions for Certain Information Returns can be read in its entirety here.
The text of 2019 Instructions for Form 1099-B can be read in its entirety here.
The text of 2019 Instructions for new forms can be read in their entirety at: Form 1098-F, 1099-LS, and Form 1099-SB.
The text of final regulations under section 6050Y can be read in their entirety here.

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The information contained herein is not intended to be “written advice concerning one or more Federal tax matters” subject to the requirements of section 10.37(a)(2) of Treasury Department Circular 230.

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