Form 1099 Reporting: 1099-B, DIV and INT Deadlines and the IRIS Switch

Form 1099 reporting for brokers, banks and fund distributors rests on three IRS information returns: Form 1099-B for broker proceeds and cost basis, Form 1099-DIV for dividends and distributions, and Form 1099-INT for interest. The Internal Revenue Service sets one calendar for all three: recipient statements by 31 January (15 February for broker statements), and the IRS copy by 28 February on paper or 31 March when filed electronically. The IRS has also set 19 November 2026 at 3 p.m. ET as the last day to file information returns through its FIRE system, making the Information Returns Intake System (IRIS) the standard electronic filing route for the 2027 filing season, subject to the IRS’s separate IDES-based submission route for eligible foreign filers.

The channel change reaches into the file itself. FIRE takes fixed-length ASCII records of 750 positions built to Publication 1220; IRIS takes XML built to IRS schemas and business rules, or entries keyed or uploaded through its portal. Each late or wrong return and each late or wrong recipient statement carries its own penalty, and a payer with ten or more information returns of any type in a year has no paper option without a waiver.

The 2026 Form 1099-B instructions send digital asset sales to Form 1099-DA, with three narrow exceptions covered under caveats below. Original issue discount has its own return, Form 1099-OID.

Related reading: Form 8966 Reporting: FATCA Filers, IDES and the 31 March Deadline

The legal basis for Form 1099 reporting: sections 6042, 6045 and 6049

Each form answers to its own section of the Internal Revenue Code. Publication 1099 (2026), the IRS general instructions for information returns, ties dividends paid under section 6042 to Form 1099-DIV and interest paid under section 6049 to Form 1099-INT. Section 6045 makes brokers report customer sales, and the Form 1099-B instructions build on Regulations section 1.6045-1 for the definitions of broker, sale, covered security and exempt recipient. The penalties for missing or wrong returns and statements sit in sections 6721 and 6722; backup withholding, at 24% according to Publication 1099, comes from section 3406.

Section 6045 also carries two rules that shape the calendar and the content. Section 6045(b) requires the broker’s written statement by 15 February, and it lets any item that would otherwise be due by 31 January move to 15 February when it is furnished with a consolidated reporting statement. Section 6045(g) adds cost basis and holding period for “covered securities”, with statutory start dates of 1 January 2011 for stock, 1 January 2012 for stock eligible for the average basis method, and 1 January 2013 or a later date set by the Secretary for other specified securities.

The e-filing mandate comes from Treasury regulations. T.D. 9972, published on 23 February 2023, cut the electronic filing threshold from 250 returns to 10, counted across all information returns, for returns required to be filed on or after 1 January 2024 (Publication 1099 and Publication 1220 both describe it).

The instructions themselves form a hierarchy, and the order matters when they disagree. Publication 1099 sets the general rules: who files, when, where, corrections, penalties. The form-specific instructions add box-level rules. For FIRE files, Publication 1220 states that where form and field instructions do not match, its guidance supersedes the form instructions. IRIS filers follow Publication 5717 (the portal user guide) or Publication 5718 (the application-to-application specifications) instead.

One version detail matters when the PDFs are read side by side: the Form 1099-B instructions are reissued each year (the current set is the 2026 edition dated 17 November 2025), while the 1099-DIV and 1099-INT instructions became continuous-use documents with the January 2024 revision and change only “as needed”.

Who must report 1099-B, 1099-DIV and 1099-INT, and who falls outside

The filer is the person responsible for the reportable payment or transaction and must use the appropriate taxpayer identification number. This is generally an EIN, although sole proprietors and nominees or middlemen who are not otherwise required to have an EIN should use their SSN. Publication 1099 requires the filer’s name and TIN on the return to match those on its other tax returns, such as the Form 945 used for backup withholding, and it bars a paying agent’s or service bureau’s name from replacing the filer’s. An agent may sign on the payer’s behalf; the payer keeps the penalty exposure.

Brokers and Form 1099-B

A broker, for Form 1099-B, is any person who in the ordinary course of a trade or business stands ready to effect sales to be made by others. The definition reaches an obligor that regularly issues and retires its own debt and a corporation that regularly redeems its own stock. It excludes a corporation buying odd-lot shares from its stockholders on an irregular basis. Barter exchanges file the same form. For a sale, redemption or retirement at an office outside the United States, only a U.S. payer or U.S. intermediary counts as a broker.

The exempt-recipient list lets brokers skip most corporate customers, and here the instructions carry a trap. For covered securities acquired after 2011, a broker cannot rely on Regulations section 1.6049-4(c)(1)(ii)(A) to decide that a customer is a corporation. It may treat the customer as exempt only where the name contains “insurance company”, “indemnity company”, “reinsurance company” or “assurance company”, the name shows a per se corporation, a Form W-9 exemption certificate shows the customer is not an S corporation, or a Form W-8 certifies a foreign corporation. Sales of covered securities acquired by an S corporation after 2011 stay reportable.

Other exceptions in the 2026 instructions are narrow and specific; they include sales of money market fund shares, fractional shares sold for less than $20, short-term obligations issued on or after 1 January 2014 (which may still need a Form 1099-INT for the interest or discount), sales initiated by dealers and financial institutions, and sales for exempt foreign persons. A broker may still file for these sales if it chooses.

Payers of dividends and interest

Form 1099-DIV goes to each person paid dividends, capital gain dividends, exempt-interest dividends or other distributions of $10 or more, each person for whom foreign tax was withheld and paid, each person subject to backup withholding on dividends, and each person paid liquidation distributions at or above a threshold discussed under caveats. Form 1099-INT applies to interest paid in the course of a trade or business, including by federal, state and local government agencies, and to interest for which the payer acted as nominee or middleman. The base threshold is $10. A higher threshold applies to trade-or-business interest that falls outside the deposit, registered-debt and similar categories listed for box 1, such as interest on delayed death benefits or on a tax refund. Backup withholding triggers a return regardless of the amount.

Forms 1099-DIV and 1099-INT generally exempt payments to specified recipients, including corporations, tax-exempt organisations, certain retirement and similar accounts, government bodies and registered securities or commodities dealers. The Form 1099-INT exemptions also cover specified nominees, custodians, brokers and swap dealers. However, the Form 1099-INT instructions require reporting tax credits of $10 or more on specified tax credit bonds even where certain otherwise-exempt recipients, including corporations and securities dealers, receive those credits.

Nominees, foreign payers and branches

A person that receives a Form 1099 for amounts that belong to someone else is a nominee and generally must file the same type of Form 1099 for each actual owner, listing itself as payer. Non-U.S. payers generally carry the same obligations as U.S. payers. Publication 1099 defines a U.S. payer to include a controlled foreign corporation, a foreign partnership whose U.S. partners together hold more than 50% of the gross income derived from the conduct of a U.S. trade or business, and a U.S. branch or territory financial institution treated as a U.S. person. Its exceptions for non-U.S. payers include foreign-source payments paid and received outside the United States, gross proceeds from sales effected outside the United States, and qualified or nonqualified intermediaries that pass enough information to another payer for that payer to file.

What the report contains: boxes, codes and the transaction grain

Forms 1099-B, 1099-DIV and 1099-INT use calendar-year reporting, with transaction-level reporting where required. An account number is mandatory when a filer has multiple accounts for a recipient and files more than one return of the same type for that recipient, or where the applicable FATCA reporting requirement calls for one. Otherwise, the IRS generally encourages, rather than requires, an account number. The granularity then differs sharply between the forms.

Form 1099-B: one form per sale, split by basis status

Form 1099-B is transactional. Brokers generally report securities transactions separately, while regulated futures, foreign currency and section 1256 option contracts are reported in aggregate. Barter exchanges report transactions involving noncorporate members or clients separately but may report transactions involving corporate members or clients in aggregate. A single sale that mixes lots must be split across separate forms for covered securities with short-term gain or loss, covered securities with long-term gain or loss, and noncovered securities where the broker checks box 5. The instructions’ own example shows one June 2026 sale of three lots producing up to three forms.

A covered security, under the 2026 instructions, is stock acquired for cash in an account after 2010, average-basis stock acquired after 2011, certain debt instruments and options acquired after 2013 and more complex ones (variable-rate, inflation-indexed, contingent payment and convertible debt among them) acquired after 2015, securities futures contracts entered into after 2013, a security transferred in with a transfer statement reporting it as covered, and a security acquired through a stock dividend, stock split, reorganization or similar corporate action whose basis is determined from the basis of a covered security. Box 5 carries the penalty consequence for noncovered sales. A broker that checks box 5 may leave boxes 1b, 1e, 1f, 1g and 2 blank, or fill them in, without penalty for errors in them. A broker that leaves box 5 unchecked is subject to sections 6721 and 6722 for those boxes even when the security sold was noncovered.

Two more box rules change the numbers. Accrued qualified stated interest on bonds sold between payment dates stays out of box 1d and goes on Form 1099-INT. Substitute payments in lieu of dividends or tax-exempt interest go in box 8 of Form 1099-MISC. The “Applicable checkbox on Form 8949” field takes a one-letter code: A, B, D or E by holding period and whether basis is reported, or X where the holding period is unknown.

Form 1099-DIV: totals by income character

Form 1099-DIV reports annual totals by character. Box 1a holds total ordinary dividends, including money market fund dividends and reinvested dividends; box 1b carries the qualified portion and cannot be negative. Box 2a holds total capital gain distributions, with boxes 2b to 2d breaking out unrecaptured section 1250 gain, section 1202 gain and 28% collectibles gain. Boxes 2e and 2f, for section 897 gain on U.S. real property interests, are for RICs and REITs only and need not be completed for U.S. individuals. The remaining boxes cover nondividend distributions (3), backup withholding (4), section 199A dividends (5), investment expenses (6), foreign tax paid and the country (7 and 8), cash and noncash liquidation distributions (9 and 10, corporations in liquidation only), the FATCA checkbox (11), and exempt-interest dividends (12 and 13).

Credit unions, cooperative banks and savings associations report the so-called dividends on deposit or share accounts on Form 1099-INT. The 1099-DIV instructions classify those amounts as interest.

Form 1099-INT: interest by tax treatment

Form 1099-INT separates taxable interest (box 1) from interest on U.S. Savings Bonds and Treasury obligations (box 3) and tax-exempt interest (box 8, with specified private activity bond interest also shown in box 9). It also carries the early withdrawal penalty (box 2), backup withholding (box 4), foreign tax (boxes 6 and 7), market discount on covered securities where the holder has notified a section 1278(b) election (box 10), bond premium amortization on covered securities (boxes 11 to 13) and the CUSIP of tax-exempt and tax credit bonds (box 14). For bond premium, the payer can report either net interest with the premium box blank or gross interest plus the premium amount; the instructions illustrate both with a $20 coupon and $2 of amortization.

Currency, signs and rounding

Every amount is in U.S. dollars. For Form 1099-B, a sale of a security traded on an established securities market is converted at the spot rate, or a reasonable spot rate convention, as of the settlement date; other foreign-currency purchase and sale amounts generally use the spot rate, or a reasonable spot-rate convention, on the applicable receipt, credit or payment date. Accrued interest and original issue discount denominated in foreign currency generally use the average exchange rate for the accrual period, subject to the specified election to use the spot rate on the last day of that period. Foreign tax on 1099-DIV and 1099-INT is also reported in U.S. dollars.

On sign, Form 1099-B shows a loss in box 1d in parentheses, and Publication 1220’s formatting rules allow negative money amounts only for Forms 1099-B, 1099-OID and 1099-Q. On Form 1099-B itself, backup withholding and bartering amounts may not be negative. On rounding, the form instructions do not set a convention. The paper-form rule in Publication 1099 is to show dollars and cents with the decimal point and no dollar sign (for example 1230.00), and to leave a box blank where no entry is required. In a FIRE file, money fields are numeric, right-justified and zero-filled.

Deadlines for Form 1099-B, 1099-DIV and 1099-INT

The reporting period is the calendar year, and the due dates are fixed each year.

Three rules move these dates. A date that falls on a Saturday, Sunday or legal holiday in the District of Columbia, or a statewide legal holiday where the return is filed, rolls to the next business day. A leap year does not shift 28 February to 29 February. For electronic filing, Publication 1099 treats a return as timely if it is submitted through IRIS by 11:59 p.m. on the due date.

Applied to the tax year 2026 cycle, the rules give these dates (derived here from the weekday calendar, so check them against the IRS tax calendar): 31 January 2027 is a Sunday, so 1099-DIV and 1099-INT statements are due Monday 1 February 2027; 15 February 2027 is the third Monday in February, which is Washington’s Birthday under 5 U.S.C. 6103, so 1099-B statements are due Tuesday 16 February 2027; 28 February 2027 is a Sunday, so paper filings are due Monday 1 March 2027; and the electronic filing date stays Wednesday 31 March 2027.

Extensions run on separate forms for the IRS copy and the recipient copy. Form 8809 gives an automatic 30-day extension to file with the IRS if it is submitted by the original due date, on paper or through IRIS, with a further 30 days available under hardship conditions. Form 15397 requests up to 30 extra days to furnish recipient statements. It goes online or by fax only, no earlier than 1 January, and must reach the IRS by the statement due date. A waiver from e-filing on Form 8508 must be submitted at least 45 days before the due date of the returns it covers.

A Transmitter Control Code (TCC) is the other lead time. Publication 1099 (2026) puts typical processing of an IRIS TCC application at 45 business days.

Submission channels: paper, the Publication 1220 format and IRIS

The e-file test counts every information return a filer must file in the calendar year, across form types. Publication 1099’s example: four Forms 1098 and six Forms 1099-A make ten, and all ten must be e-filed. Corrected returns do not count toward the ten, according to Publication 1220, but corrections to e-filed originals must themselves be e-filed. Filing on paper when e-filing was required is itself a failure under section 6721, though the e-file penalty applies only to the returns above ten.

Paper filing

Paper filers send Copy A with a separate Form 1096 for each form type. The IRS reads paper forms by optical character recognition, so Copy A of Forms 1099-B, 1099-DIV and 1099-INT printed from IRS.gov cannot be filed. The online-fillable exception in Publication 1099 covers low-volume forms such as 1099-CAP and 1099-LTC, and these three are not on it.

FIRE and Publication 1220

Publication 1220 (Rev. 5-2026), labelled for tax year 2025, specifies the FIRE file. Every record is 750 positions in standard ASCII; a file runs Transmitter “T”, Issuer “A”, Payee “B”, End of Issuer “C”, optional State Totals “K” for the Combined Federal/State Filing Program, and End of Transmission “F”. The “A” record carries the type of return code (B for 1099-B, 1 for 1099-DIV, 6 for 1099-INT) and the amount codes used in the “B” records. A file may hold up to one million records. Compression is limited to WinZip or PKZIP, one file per archive.

On file naming, FIRE overrides the transmitter. Transmitters may name their own files, but the system assigns a unique name built from the submission type, the TCC and a four-digit sequence number, for example ORIG.44444.0001 for the first original file of the year from TCC 44444. That assigned name is the reference the IRS asks for when a file needs help.

IRIS portal and A2A

IRIS has two doors. The Taxpayer Portal lets a filer key or upload by .csv up to 100 returns per submission, print recipient copies, request extensions and take part in the Combined Federal/State Filing Program. The application-to-application (A2A) channel takes XML transmissions of up to 100 MB through software, under Publication 5718. Each A2A submission must contain one form type and one tax year, a transmission cannot mix originals, corrections and replacements, and the return count in the submission header must match the records sent. Both IRIS channels require an IRIS TCC, and the IRS lists Forms 1099-B, 1099-DIV and 1099-INT among the accepted forms.

Separately, the IRS offers the Foreign Filer TCC Registration System and an IDES submission route for foreign filers whose authorised users do not have a US SSN or ITIN and so cannot apply for an IRIS TCC directly. Filers whose authorised users have an SSN or ITIN must apply through IRIS and must not use that system.

Publication 1220 lists Forms 1099-B, 1099-DIV and 1099-INT among the returns eligible for the Combined Federal/State Filing Program, under which the IRS forwards returns to participating states. State filing requirements still apply; the program changes the route, and each state sets its own rules.

Recipient statements

The statement rules differ by form. Recipient statements may be furnished using the official form or an acceptable substitute, in person, by First-Class Mail or electronically where permitted. Publication 1099’s special mailing and enclosure restrictions apply to Forms 1099-DIV other than section 404(k) dividends and Forms 1099-INT other than trade-or-business interest reportable under section 6041. The excluded categories follow the separate recipient-statement rules in the same publication.

Within the restricted categories, Publication 1099 rules out advertising, and the legend “Important Tax Return Document Enclosed” is required on the envelope unless the mailing contains only statements, Forms W-8 and W-9 and a tax-consequences letter. Form 1099-B statements may be combined with other reports, and a broker may give each customer one set of instructions covering every 1099-B statement for the year. Brokers may also put sales, interest, dividends and foreign tax on a single substitute statement under Publication 1179.

Electronic delivery needs the recipient’s affirmative consent, given electronically in a way that shows the recipient can open the format used. The statement must stay posted through 15 October of that year. Payee TINs may be truncated on statements; the copy filed with the IRS carries the full number.

Validation and rejection: file status, replacements and corrections

Validation happens in layers. The channel checks the file’s structure, the IRS later matches names and TINs, and penalties apply to whatever gets through wrong. The rejection causes below come from the IRS’s own “Common Problems” and “Common Formatting Errors” tables in Publication 1220 and the common-errors list in Publication 1099.

FIRE results and replacement files

FIRE posts results within two business days, slower at peak: Good, Bad, or Not Yet Processed. A Bad file is replaced, in full, by a replacement file. If an acceptable replacement arrives within 60 days of the original transmission, the original transmission date counts for penalty purposes. A correction file is a different thing: it carries only the records that need correcting, and only against returns already processed as Good. Resending a whole file as a correction appears in the Common Problems table.

The formatting errors Publication 1220 lists include “C” record control totals that do not equal the “B” record totals, amount codes in the “A” record that do not match the money fields used in the “B” records, a missing or invalid issuer TIN, the wrong tax year in positions 2 to 5, a test indicator left in a production file, and a large share of missing or obviously invalid payee TINs, which can stop the file from processing. EBCDIC and PDF files fail the standard ASCII requirement.

Corrections in FIRE use one transaction for wrong amounts, codes, indicators or a return that should not have been filed: a “G” coded record with the correct data. A missing or wrong payee TIN, a wrong payee name or the wrong type of return takes two transactions: first a “G” coded record that repeats the original with zero amounts, then a “C” coded record with the correct information. The account number must match the original return so the IRS can find it.

IRIS acknowledgements

IRIS returns one of six statuses: Accepted, Rejected, Processing, Partially Accepted, Accepted with Errors, or Not Found. IRIS rejection handling depends on the validation stage. When IRIS rejects a transmission before issuing a Receipt ID, the transmitter must correct the error and resubmit using the same TransmissionTypeCd as the rejected transmission. Publication 5718 separately states that a transmission rejected for an XML Schema Validation Error cannot be replaced and must be resubmitted as an original. Other rejected transmissions and rejected submissions within a Partially Accepted transmission follow the applicable replacement procedures. Where the replacement procedure applies, an acceptable replacement received within 60 days of the rejected status becoming available retains the original receipt date for penalty purposes.

Corrections apply only to records Accepted or Accepted with Errors, and a further correction to the same record references the most recently accepted correction. The correction logic also differs from FIRE: under Publication 5718 a wrong payee name or TIN is a one-step correction in IRIS, and only a wrong form type needs two steps. Its schema rules add a version trap: returns composed under a superseded major schema version are rejected, while returns built on an earlier minor version are validated against the latest one.

Publication 5718 (Rev. 1-2026) requires originals filed through FIRE to be corrected through FIRE. The IRS has since confirmed that FIRE will no longer accept submissions after its retirement and that IRIS will handle prior-year returns and corrections from 1 January 2027. The IRS FIRE page does not set out a record-level procedure for correcting a return originally filed through FIRE. At its 12 August 2026 IRIS Working Group meeting, the IRS said that a corrected return sent through IRIS for a record originally accepted by FIRE must complete the PrevSubmittedRecRecipientGrp element, with OtherIntakeSystemInd set to true and OtherIntakeSystemNm identifying the prior intake system, and that further detail will appear in Publication 5718 and the TY26/PY27 schema packages. Filers should confirm that detail before attempting such corrections.

Paper corrections and payer errors

Paper corrections follow the error charts in Publication 1099: Error Type 1 (wrong money amount, code or checkbox, or a return filed in error) takes one corrected return, while Error Type 2 (no or wrong payee TIN, wrong payee name, or the wrong form, such as a 1099-DIV filed where a 1099-INT was due) takes two. An error in the payer’s own name or TIN is handled separately: Publication 1220 directs FIRE filers to write to the IRS at Kearneysville, and Publication 1099 points IRIS filers to Publication 5718.

What an error costs

For ordinary Form 1099-B, 1099-DIV and 1099-INT reporting, sections 6721 and 6722 generally impose separate penalties for failures involving IRS returns and recipient statements. Publication 1099 (2026) places Form 1099-B filed solely for qualified opportunity fund reporting under section 1400Z-2 in its section 6693 category and states that sections 6721 and 6722 do not apply to it. The IRS publishes the amounts by the year the return is due.

Two relief rules limit exposure. Under the de minimis correction rule, timely filed returns that are corrected by 1 August escape the incorrect-information penalty for the greater of 10 returns or 0.5% of the returns required for the year. Under the safe harbor for de minimis dollar errors, an amount within $100 of the correct figure, or withholding within $25, needs no correction unless the recipient elects a corrected statement. Errors in a TIN, a payee surname or a money amount outside that safe harbor are never treated as inconsequential.

Caveats: thresholds, FATCA elections and overlapping forms

The $600 and $2,000 mismatch

The current documents disagree on two thresholds. Publication 1099 (2026) says that for tax years beginning after 2025 the minimum threshold for reporting certain payments, and for backup withholding on them, rose to $2,000, adjusted for inflation from calendar year 2027. Its Guide to Information Returns accordingly shows $2,000 for 1099-DIV liquidation distributions and “$2,000 or more in some cases” for 1099-INT. The continuous-use instructions, still at their January 2024 revision on the IRS form pages, print $600 for liquidations and for interest paid in the course of a trade or business.

Publication 1099 (2026) carries the later rule for tax year 2026 payments. The $10 base thresholds for dividends and interest are unchanged in both documents.

FFIs reporting U.S. accounts on Form 1099

A participating FFI, or a registered deemed-compliant FFI other than a Reporting Model 1 FFI, may elect to report a U.S. account held by a specified U.S. person on Forms 1099 instead of Form 8966. Accounts of passive NFFEs that are U.S.-owned foreign entities, and accounts held by owner-documented FFIs, stay on Form 8966. An electing FFI must use its EIN (never its GIIN), check the FATCA box, report the account number, and add the branch jurisdiction after its name where a branch maintains the account. An account with no reportable payments, or payments below the form thresholds, is reported on Form 1099-MISC or 1099-NEC. The election leaves the FFI’s chapter 61 obligations as a payer in place.

Reporting Model 1 FFIs are outside the election. Luxembourg signed a Model 1 agreement on 28 March 2014, and its financial institutions file their FATCA return with the Administration des contributions directes, the route set out in our FATCA reporting guide for Luxembourg.

Payments to foreign persons and through intermediaries

Payments to foreign persons are reported on Form 1042-S where they fall within that form’s applicable US-source income, withholding or other specified reporting rules. Foreign status alone does not make every payment reportable on Form 1042-S; foreign-source income generally falls outside its reporting scope, subject to specified exceptions. Publication 1099 says income reported on Form 1042-S must not be repeated on Forms 1099. When documentation is missing, the presumption rules decide: a payee presumed to be a U.S. nonexempt recipient gets a 1099, switched to a 1042-S if documented as foreign before filing. A payer paying through a qualified or nonqualified intermediary for a known U.S. recipient enters “IMY” and the intermediary’s name on the second name line. Where the recipient is unknown, the first line reads “unknown recipient” and the TIN box carries the intermediary’s EIN where it has one.

Where 1099-B ends and other forms begin

The 2026 Form 1099-B instructions route digital asset sales to Form 1099-DA, including dual classification assets that are also securities. Three exceptions keep a 1099-B: assets that are digital only because they clear or settle on a limited access regulated network, Section 1256 contracts on digital assets (reported in aggregate on 1099-B, with any delivery of the underlying digital asset reported on 1099-DA), and money market fund shares (no 1099-DA; a 1099-B is optional). Tokenized securities go on 1099-DA. For dispositions of digital assets held by a WHFIT, trustees and middlemen may use either form. Firms with non-U.S. crypto customers face a separate regime under the OECD standard, covered in our guide to CARF crypto tax reporting.

Income earned inside an IRA, Coverdell ESA, ABLE account, Archer MSA or HSA is generally kept off Forms 1099; only distributions are reported, on Forms 1099-R, 1099-Q, 1099-QA or 1099-SA.

Backup withholding

Backup withholding at 24% applies in the cases listed in Publication 1099, including where a payee fails to furnish a TIN, fails to certify it for accounts opened after 1983, fails to certify for interest and dividend accounts opened after 1983 that it is not subject to backup withholding, or the IRS gives notice of an incorrect TIN or underreporting. A payer that receives an IRS notice of an incorrect name/TIN combination must send the payee a “B” notice and must start withholding on payments made more than 30 business days after receiving the IRS notice. Withholding is reported on Form 945 and on the 1099 itself, even when the payment is below the normal reporting threshold, and the EIN on the 1099 must match the Form 945 filer. Publication 1099 points to TIN Matching through IRS e-services as the pre-filing check, anticipating fewer CP2100 backup withholding notices for payers that use it.

Changes to Form 1099-B, 1099-DIV and 1099-INT filing

Publication 1099 (2026) has already removed its references to FIRE and Publication 1220, and it points e-filers to Publications 5717 and 5718. For a payer that has built its 1099 output around the Publication 1220 record layout, the format change is the substantive one. IRIS validates XML against schemas and business rules and marks originals, corrections and replacements with a TransmissionTypeCd of O, C or R and corrected records with a CorrectedInd, in place of the FIRE record codes.

Publication 5718 requires each tax year’s returns to be built on the schemas and business rules in effect for that tax year, and it bars mixing tax years in one transmission or submission. For tax year 2026, the IRS lists IRIS schema and business-rule package 2026v1.2, available in its Secure Object Repository from 24 September 2026, with Assurance Testing System availability from 5 October 2026 and production scheduled for January 2027. Separately, effective 7 October 2026, IRIS transmissions for tax years 2022 through 2026 must use SchemaVersionNum 5.0.7. Access to the schema files requires the appropriate authorised Secure Object Repository credentials, so filers should verify the latest applicable release before testing or submitting XML.

Frequently Asked Questions

A customer transferred shares in from another broker without a transfer statement. Do we report basis on the eventual sale?

The transferring firm owes a transfer statement within 15 days after settlement, and the receiving broker must ask for one if it is late. If no complete statement arrives, the 1099-B instructions let the receiving broker treat the shares as noncovered. A statement that arrives later showing the shares as covered requires a corrected Form 1099-B within 30 days, unless it arrives more than 3 years after the original was filed.

An issuer posts a Form 8937 basis adjustment after our 1099-Bs have gone out. Must we correct?

Yes, within 30 days of receiving or being deemed to receive the issuer statement, unless that is more than 3 years after the original filing. Only organisational actions during the period the broker held custody count. An issuer that posts the return on its public website by the due date, and keeps it there for 10 years, need not file Form 8937 with the IRS. The instructions count statements the broker is deemed to receive as well as those it actually receives.

A short sale opened in December is still open on 31 December. Does it go on this year’s 1099-B?

Only if backup withholding was taken from the gross proceeds when it opened. In that case a 1099-B for the opening year shows the withholding in box 4 and a brief description in box 1a, with the other numbered boxes blank. The full sale is reported for the year the customer delivers the security, without repeating the earlier withholding.

One order filled at several prices on the same day. Which proceeds per share do we report?

Where a single trade order is executed in pieces on one calendar day and the customer gets one confirmation showing an aggregate or average price, the broker may average the proceeds per share. It cannot do so if the customer notifies it in writing, by 15 January of the following year, that the customer will use actual proceeds per share. The broker may extend that date, but not beyond the 1099-B filing due date.

A new customer wrote “Applied For” in the TIN box of Form W-9. Do we backup withhold on its dividends?

That signed form is an awaiting-TIN certificate, and for interest, dividends and certain payments on readily tradable instruments the payee has 60 days to supply the TIN. If it has not arrived by then, withholding starts and continues until it does. Publication 1099 calls this a 60-day exemption, limits it to those payment types, and refers to Regulations section 31.3406(g)-3 on whether withholding applies during the period.

We bought another broker’s business mid-year. Does each firm file its own 1099s?

The two firms can agree otherwise. Under the combined reporting procedure of Rev. Proc. 99-50, a successor that acquires substantially all the property used in the predecessor’s business may agree to file one return per recipient, combining both firms’ amounts and withholding for the acquisition year, and the agreement may be limited to specific forms or business units. For transactional forms such as 1099-B, each transaction is still reported. The successor must also send the IRS a statement listing the forms filed on a combined basis by the forms’ due dates.

A REIT declared a dividend in December but paid it in January. Which year’s 1099-DIV, and which year’s Form 945?

A RIC or REIT dividend declared in October, November or December, payable to holders of record on a date in that month and actually paid in January, is reported on the 1099-DIV for the earlier year. Backup withholding on it is taken when the dividend is paid in January and reported on Form 945 for that later year, yet it also appears on the prior-year 1099-DIV.

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Key Takeaways

• Ordinary electronic filers should obtain an IRIS TCC before the 2027 filing season; eligible foreign filers whose authorised users lack a US SSN or ITIN should use the separate Foreign Filer TCC and IDES route. FIRE accepts its final submission on 19 November 2026. For returns originally accepted by FIRE, the IRS said on 12 August 2026 that IRIS corrections must complete the PrevSubmittedRecRecipientGrp element, and filers should confirm the further detail in Publication 5718 and the TY26/PY27 schema packages before correcting them.
• Count every information return across all form types: ten or more in a calendar year removes the paper option for all of them unless a Form 8508 waiver is approved.
• Dividend and interest items furnished with a consolidated broker statement move from 31 January to 15 February under section 6045(b).
• For noncovered securities reported on a separate Form 1099-B, checking box 5 is permitted and removes penalties for errors in the specified optional basis and holding-period fields. Do not check box 5 when reporting covered securities; the 2026 instructions also permit certain noncovered securities to be reported together with covered long-term securities, in which case box 5 cannot be checked.
• A rejected FIRE file keeps its original date only if an acceptable replacement follows within 60 days; IRIS applies the same 60-day rule only where the replacement procedure applies, and XML schema-validation rejections are resubmitted as originals.
• Record which source drives the 1099-DIV liquidation and 1099-INT trade-or-business triggers: Publication 1099 (2026) shows $2,000, the January 2024 instructions still print $600.
• Electing FFIs report U.S. accounts on Form 1099 under their EIN, never the GIIN, with the account number on every return.

Sources and References

• IRS, Publication 1099 (2026), General Instructions for Certain Information Returns, 19 March 2026 (also the source for the references to T.D. 9972, T.D. 9504 and Rev. Proc. 99-50 used in this article): https://www.irs.gov/pub/irs-pdf/p1099.pdf
• IRS, Instructions for Form 1099-B (2026), 17 November 2025: https://www.irs.gov/pub/irs-pdf/i1099b.pdf
• IRS, Instructions for Form 1099-DIV (Rev. January 2024): https://www.irs.gov/pub/irs-pdf/i1099div.pdf
• IRS, Instructions for Forms 1099-INT and 1099-OID (Rev. January 2024): https://www.irs.gov/pub/irs-pdf/i1099int.pdf
• IRS, Publication 1220 (Rev. 5-2026), Specifications for Electronic Filing of Forms 1097, 1098, 1099, 3921, 3922, 5498 and W-2G, for tax year 2025: https://www.irs.gov/pub/irs-pdf/p1220.pdf
• IRS, Publication 5718 (Rev. 1-2026), IRIS Electronic Filing Application to Application (A2A) Specifications, Processing Year 2026: https://www.irs.gov/pub/irs-pdf/p5718.pdf
• IRS, Filing Information Returns Electronically (FIRE), retirement key dates: https://www.irs.gov/e-file-providers/filing-information-returns-electronically-fire
• IRS, E-file information returns with IRIS: https://www.irs.gov/filing/e-file-information-returns-with-iris
• IRS, IRIS schemas and business rules: https://www.irs.gov/e-file-providers/iris-schemas-and-business-rules
• IRS, Rev. Proc. 2025-32, Internal Revenue Bulletin 2025-45 (sections 4.57 and 4.58): https://www.irs.gov/irb/2025-45_IRB
• IRS, Instructions for Form 1042-S (2026), Foreign Person’s U.S. Source Income Subject to Withholding: https://www.irs.gov/instructions/i1042s
• IRS, Foreign Filer TCC Registration: https://www.irs.gov/filing/foreign-filer-transmitter-control-code-tcc-registration
• IRS, IRIS Working Group meeting, 12 August 2026: https://www.irs.gov/pub/irs-efile/iris-working-group-meeting-08122026.pdf
• IRS, Information return penalties: https://www.irs.gov/payments/information-return-penalties
• IRS, About Form 1099-DIV: https://www.irs.gov/forms-pubs/about-form-1099-div
• IRS, About Form 1099-INT: https://www.irs.gov/forms-pubs/about-form-1099-int
• Administration des contributions directes (Luxembourg), FATCA page, Model 1 agreement signed 28 March 2014: https://impotsdirects.public.lu/fr/echanges_electroniques/FATCA.html
• 26 U.S.C. 6045, Returns of brokers (subsections (b) and (g)): https://www.law.cornell.edu/uscode/text/26/6045
• 5 U.S.C. 6103, Holidays: https://www.law.cornell.edu/uscode/text/5/6103

Preparing for the IRIS-based Form 1099 filing season

Tax year 2026 requires an updated electronic-filing process. Ordinary electronic filers need an IRIS TCC and an IRIS-compliant XML or portal workflow; eligible foreign filers whose authorised users lack a US SSN or ITIN use the IRS’s separate Foreign Filer TCC and IDES route. Filers should also confirm the Publication 5718 and TY26/PY27 schema detail on correcting returns originally accepted by FIRE, which the IRS previewed on 12 August 2026. For tax year 2026, Forms 1099-DIV and 1099-INT must generally be furnished to recipients by Monday 1 February 2027, and Form 1099-B by Tuesday 16 February 2027. The ordinary electronic IRS filing deadline for all three is Wednesday 31 March 2027.

Disclaimer: The information on RegReportingDesk.com is for educational and informational purposes only. It does not constitute legal, regulatory, tax, or compliance advice. Always consult your compliance officer, legal counsel, or the relevant supervisory authority for guidance specific to your institution.