Information Reporting After OBBBA: 1099s, Thresholds, Form 1099-DA, and Filing Against a Wrong Form

About the course

The Form 1099 in hand is not always the return the client has to file. OBBBA revised the reporting thresholds for Forms 1099-K, 1099-NEC, and 1099-MISC, and introduced Form 1099-DA for digital asset transactions under IRC §6045 and Rev. Proc. 2024-28. Payors are working through the new rules and issuing forms that sometimes report the wrong amount, the wrong classification, or amounts that belong on a different form entirely. The preparer's job is knowing which reported number to accept, which to challenge, and how to document a return that departs from what the 1099 shows.

This course covers the current-year information reporting landscape. Coverage includes the revised thresholds and reporting requirements under the OBBBA-updated rules for Forms 1099-K, 1099-NEC, and 1099-MISC, the mechanics of new Form 1099-DA for digital asset transactions, the penalty structure under IRC §6721 and §6722 for payor information return failures, and the safe harbor and reasonable-cause standards that limit payor penalty exposure.

The course closes with the recipient's remedies when a Form 1099 in hand reports an incorrect amount or classification, and the documentation a preparer maintains when filing a return that departs from what a Form 1099 shows. Two hours of Federal Tax credit.

Learning objectives

By the end of this course, participants will be able to:

1. Identify the revised reporting thresholds under OBBBA for Forms 1099-K, 1099-NEC, and 1099-MISC.
2. Recognize the information reporting requirements for digital asset transactions under IRC §6045 and Rev. Proc. 2024-28, including Form 1099-DA.
3. Identify the payor penalty structure under IRC §6721 and §6722 for information return failures, including safe harbor and reasonable-cause provisions.
4. Recognize the recipient's options when a Form 1099 in hand reports an incorrect amount or classification.
5. Identify the documentation practices required to substantiate a return filing that departs from an issued Form 1099.

Syllabus

1. SECTION 01The reporting-vs-return frame

   Why the 1099 does not control the return, when the reported number is correct and when it is not, and where the preparer's judgment attaches.

2. SECTION 02Revised thresholds under OBBBA

   Updated reporting requirements for Forms 1099-K, 1099-NEC, and 1099-MISC, including current threshold amounts and transaction-type distinctions.

3. SECTION 03Form 1099-DA and digital asset reporting

   Digital asset transaction reporting under IRC §6045 and Rev. Proc. 2024-28, brokers subject to the requirement, and the transaction detail Form 1099-DA reports.

4. SECTION 04Payor penalties under §6721 and §6722

   The penalty structure for information return failures, the safe harbor provisions, and the reasonable-cause standard payors raise to limit exposure.

5. SECTION 05When the 1099 is wrong

   Recipient options — including requesting a corrected form and filing a return that departs from the 1099 — and the timing and documentation the recipient's preparer needs.

6. SECTION 06Substantiation for departing filings

   Workpapers, source documents, and correspondence a preparer maintains when a return filing does not match a Form 1099 in hand.

Instructor

Jennifer Harris Smith, JD, CPA. Attorney (Texas). CPA (Texas). Member of Texas Bar College. Full bio →