New Submission Requirements for Forms 1099-MISC

Higher Education|Internal Revenue Service|Not-for-Profit|Schneider Downs|Tax

By Sarah Piot

The Protecting Americans from Tax Hikes (PATH) Act of 2015 updated the due date filing requirements for Forms 1099-MISC as follows:

  • January 31 - Reporting non-employee compensation (Box 7), whether filed on paper or electronically
  • February 28 – Not reporting non-employee compensation (all boxes except Box 7) and filed on paper
  • March 31 - Not reporting non-employee compensation (all boxes except Box 7) and filed electronically

Effective for tax year 2018, it is required that all Form 1099-MISC submissions after January 31, 2019 reporting non-employee compensation in Box 7 be filed separately from other Forms 1099-MISC with reporting in other boxes.  Therefore, if filing on paper, separate submissions are required, each with its own Form 1096.  If filing electronically, separate submissions are required, each with its own Payer “A” Record.

It is important that Forms 1099-MISC be submitted in accordance with IRS transmission rules above. Organizations that submit mixed submissions (those with both Box 7 and other boxes completed) may receive a Notice 972CG, treating all Forms 1099-MISC subject to the Section 6721 penalty for failure to file by January 31.

Penalties for late filing vary based on the gross receipts of an organization and the number of days the filing is late but can be significant.  

Organizations may provide recipients with a single payee statement reporting all Form-MISC payment types even if they report two separate forms with the IRS.  The due date for providing payees Forms 1099-MISC is January 31.

If you have any questions or would like to discuss these regulations in further detail, please contact your Schneider Downs representative.

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