Due to new IRS regs, employers will be subject to stricter e-filing requirements in 2024. Find out what’s coming and check out the list of forms.
When the Service released final regs on February 23, 2023, it came as a surprise that the e-filing threshold would drop suddenly to 10 returns.
You may recall that, under proposed regs issued July 23, 2021, the plan was to decrease the threshold gradually – from 250 returns, to 100, to 10.
But that’s not how the situation unfolded.
The sudden decrease in the e-filing threshold will require quick action on your part. The change will be on your plate starting in calendar year 2024.
There’s another dimension to the final regs which – although not a surprise – will pose challenges for employers. Specifically, businesses will need to aggregate forms to determine if they’ve met the 10-return threshold for electronic filing.
Proactive, internal communication will be key for businesses, in light of the aggregation rule. After all, various departments may carry the responsibility for submitting these returns.
Forms to aggregate under e-filing rule
Which forms must employers include to comply with the new aggregation rule for e-filing?
We’ve created this checklist for you.
Count the number of returns you must file for each form on this list. If you reach 10 returns, that means you’ll need to e-file all the forms on the list starting in calendar year 2024, according to the final IRS regs.
These are the forms:
- 1042-S, Foreign Person’s U.S. Source Income Subject to Withholding
- 1094-B, Transmittal of Health Coverage Info Returns
- 1094-C, Transmittal of Employer-Provided Health Insurance Offer and Coverage Info Returns
- 1095-B, Health Coverage
- 1095-C, Employer-Provided Health Insurance Offer and Coverage
- 1097-BTC, Bond Tax Credit
- 1098, Mortgage Interest Statement
- 1098-C, Contributions of Motor Vehicles, Boats, and Airplanes
- 1098-E, Student Loan Interest Statement
- 1098-Q, Qualifying Longevity Annuity Contract Information
- 1098-T, Tuition Statement
- 1099-A, Acquisition or Abandonment of Secured Property
- 1099-B, Proceeds from Broker and Barter Exchange Transactions
- 1099-C, Cancellation of Debt
- 1099-CAP, Changes in Corporate Control and Capital Structure
- 1099-DIV, Dividends and Distributions
- 1099-G, Certain Government Payments
- 1099-H, Health Coverage Tax Credit Advance Payments
- 1099-INT, Interest Income
- 1099-K, Payment Card and Third-Party Network Transactions
- 1099-LS, Reportable Life Insurance Sale
- 1099-LTC, Long-Term Care and Accelerated Death Benefits
- 1099-MISC, Miscellaneous Income
- 1099-NEC, Nonemployee Compensation
- 1099-OID, Original Issue Discount
- 1099-PATR, Taxable Distributions Received from Cooperatives
- 1099-Q, Payments from Qualified Education Programs (Under Section 529 and 530)
- 1099-QA, Distributions from ABLE Accounts
- 1099-R, Distributions from Pensions, Annuities, Retirement or Profit-Sharing Plans, IRAs … etc.
- 1099-S, Proceeds from Real Estate Transactions
- 1099-SA, Distributions From an HSA, Archer MSA, or Medicare Advantage MSA
- 1099-SB, Seller’s Investment in Life Insurance Contract
- 3921, Exercise of an Incentive Stock Option Under Section 422(b)
- 3922, Transfer of Stock Acquired Through An Employee Stock Purchase Plan Under Section 423(c)
- 5498, IRA Contribution Information
- 5498-ESA, Coverdale ESA Contribution Information
- 5498-QA, ABLE Account Contribution Information
- 5498-SA, HSA, Archer MSA, or Medicare Advantage MSA Information
- 8027, Employer’s Annual Info Return of Tip Income and Allocated Tips
- W-2G, Certain Gambling Winnings
- W-2, Wage and Tax Statement
- W-2AS, American Samoa Wage and Tax Statement
- W-2GU, Guam Wage and Tax Statement
- W-2VI, U.S. Virgin Islands Wage and Tax Statement, and
- 499R-2/W-2PR, Withholding Statement (Puerto Rico).
Platforms for electronic filing
The lower e-filing threshold, set to take effect for Tax Year 2023, is possible in part due to the new Information Returns Intake System (IRIS). As brought about by the Taxpayer First Act, IRS first got this platform for e-filing 1099s up and running for Tax Year 2022.
IRIS was modeled after Business Services Online, which employers use to e-file W-2s with the Social Security Administration.
