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NACUBO Comments to IRS on Expanded Form 1099 Reporting Requirements

October 6, 2010

On September 29, NACUBO filed comments to IRS in response to Notice 2010-51. The notice addresses implementation of expanded Form 1099 requirements enacted earlier this year as part of the Affordable Care Act of 2010. The new provision extends existing reporting requirements to apply to payments made to corporations and to include certain payments of gross proceeds with respect to goods and other property. The new reporting requirements apply to payments made after December 31, 2011.

NACUBO's comments articulate:

• support for the exemption of purchasing card transactions (already endorsed by Treasury in proposed banking rules);
• a request for clarification that all nonprofit and public colleges and universities are exempted from receiving 1099s;
• a recommendation that students and individuals participating in course material buyback programs be expressly exempt from receiving Forms 1099;
• a request that vendors of goods, services, and other property be given the opportunity to receive the Form 1099 electronically;
• a request for a substantial increase in the annual reporting threshold from $600 to $5,000; and
• a recommendation that the new reporting requirements be postponed for one year for reporting the payment of services to corporations and three years for reporting the purchase of goods and other property.

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Mary Bachinger
Director, Tax Policy
202.861.2581
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