IRS Updates Publication 1220

Nicolette Chasse
January 26, 2018

The IRS recently updated Publication 1220, "Specifications for Electronic Filing of Forms 1097, 1098, 1099, 3921, 3922, 5498, and W-2G."   Additional information has been added regarding the new Form 8809 as well as Notice 2018-06. 


A new section has been introduced, providing important filing guidance for TY 2017 for Form 1099-MISC non-employee compensation (NEC).  According to the new Section 7 in Part A, the PATH Act of 2015 requires Forms 1099-MISC reporting non-employee compensation (NEC) in box 7 to be filed by January 31.  After January 31, if you transmit a Form 1099-MISC reporting NEC and other Forms 1099-MISC that do not report NEC together with a single Payer ‘A’ Record, the IRS may inadvertently treat each form transmitted with the Payer ‘A’ Record as if it is subject to the section 6721 penalty for failure to file by January 31, even though many of the forms might not be due until March 31. 


The IRS recommends the following to alleviate the issue described above: If any Forms 1099-MISC reporting NEC will be filed after the January 31, 2018 due date, separate the transmission of the Forms 1099-MISC from the transmission that do not report NEC and are not due until April 2, 2018.  This procedure will become mandatory for all Form 1099-MISC transmissions submitted after January 31, 2019.


A new section has been added to Part B, Section 3, regarding Secret Phrases.  Starting this year, FIRE accounts will be required to established a secret phrase to assist in resetting passwords for FIRE Systems.


To read Publication 1220 in full, please follow the link.

Sign up for Email Updates

Stay up to date with the latest tax and compliance updates that may impact your business.


Nicolette Chasse

Nicolette Chasse is a Junior Regulatory Counsel at Sovos Compliance. Her main areas of focus are Automatic Exchange of Information (AEOI) reporting under FATCA and CRS and 1099 Federal Withholding Reporting. Nicolette received her B.A. at Trinity College and her J.D. at Penn State’s Dickinson School of Law. She is a member of the Massachusetts Bar.
Share This Post