Form 1099-MISC 2019 Checklist
Purpose
Form 1099-MISC reports miscellaneous income, including rents, royalties, nonemployee compensation, and legal fees. The 2019 tax year introduced a critical due-date split: furnish Copy B to recipients by January 31, 2020, but file Copy A with the IRS by January 31 only if reporting box 7 payments; otherwise, file by February 28, 2020 (paper) or March 31, 2020 (electronic). An extended deadline of February 18, 2020, applies when reporting box 8 or box 14 payments.
Payer Reporting Steps
Step 1: Verify Recipient Taxpayer Identification Numbers
Obtain and verify the recipient’s TIN using Form W-9 or equivalent documentation. For 2019, you may truncate the recipient’s SSN, ITIN, ATIN, or EIN to display only the last four digits on Copy B furnished to recipients. However, you must report the complete TIN to the IRS on Copy A. Failure to obtain a TIN may subject you to backup withholding requirements and potential penalties.
Step 2: Determine Box 7 Reporting Requirements
Report box 7, nonemployee compensation, if payments total $600 or more during the calendar year. This includes fees, commissions, prizes, and awards for services performed as a nonemployee, cash purchases of fish, and oil and gas payments for a working interest. If box 7 contains reportable amounts, you must file Copy A with the IRS by January 31, 2020, using either paper or electronic filing procedures.
Step 3: Report Box 14 Gross Proceeds to Attorneys
Report box 14 when payments to an attorney total $600 or more and meet specific criteria. These payments must be made in connection with legal services but not for the attorney’s own services, such as settlement payments. Do not include amounts already reportable in box 7. The $600 threshold applies to gross proceeds payments under section 6045(f). When box 14 contains reportable amounts, the deadline to furnish Copy B to recipients is extended to February 18, 2020.
Step 4: Report Box 8 Substitute Payments
Report box 8 when a broker makes substitute payments instead of dividends or tax-exempt interest on loaned securities. These payments arise when securities are lent, and the borrower makes substitute payments to compensate for dividends or interest the lender would have received. The reporting threshold is $10 or more. When box 8 contains reportable payments, the deadline to furnish Copy B to recipients is extended to February 18, 2020.
Step 5: Complete Section 409A Boxes
Report box 15a (Section 409A deferrals) only if you choose to complete this optional box. If completed, enter the total amount deferred during the year of at least $600 for the nonemployee under all nonqualified deferred compensation plans, including earnings on current and prior year deferrals. Report box 15b (Section 409A income) for amounts includible in income because the NQDC plan fails to satisfy section 409A requirements. Amounts in box 15b must also be included in box 7, as they represent currently taxable nonemployee compensation.
Step 6: Report Other Boxes as Applicable
Complete additional boxes based on payment types. Report box 1 for rents of $600 or more, box 2 for royalties of $10 or more, box 3 for other income of $600 or more including prizes and awards, box 4 for federal income tax withheld under backup withholding rules, box 5 for fishing boat proceeds, box 6 for medical and health care payments of $600 or more, and box 10 for crop insurance proceeds of $600 or more.
Step 7: Furnish Copy B to Recipients by the Applicable Deadline
Provide Copy B to each recipient by January 31, 2020, for most payment types. If you report payments in box 8 or box 14, the deadline to furnish Copy B extends to February 18, 2020. You may provide statements by mail, hand-delivery, or electronically if the recipient consents. Online fillable PDF copies are available at IRS.gov/Form1099MISC to ease statement-filing requirements. Ensure recipients receive their statements by the applicable deadline to avoid penalties.
Step 8: Prepare Copy A for IRS Filing
Use official IRS forms for paper filing. Do not print Copy A from the IRS website because these forms lack the scannable format required for IRS processing equipment. Order official scannable forms from the IRS or use IRS-approved substitute forms. If you print forms from the website, they will be rejected during processing, and you may incur penalties. Alternatively, can you file electronically to avoid the requirement for a scannable form?
Step 9: File Copy A with the IRS by the Correct Deadline
File Copy A with the IRS using deadline rules based on your reporting. If box 7 contains reportable nonemployee compensation, file by January 31, 2020. For all other reported payments without box 7 amounts, file by February 28, 2020, if filing on paper, or March 31, 2020, if filing electronically. Separate your transmissions: file Form 1099-MISC reporting box 7 separately from forms without box 7 to avoid late-filing penalties on all forms in a mixed transmission.
Step 10: Complete Form 1096 for Paper Filers
Prepare Form 1096 as a transmittal document if filing paper forms. Form 1096 summarizes all paper Forms 1099-MISC you are sending to the IRS. Complete a separate Form 1096 for each type of form (do not combine different 1099 types on one transmittal). Send Copies A of all Forms 1099-MISC together with the completed Form 1096 to the IRS address specified in the instructions. Form 1096 is not required for electronic filers.
Step 11: File Electronically if Required
File electronically if you are submitting 250 or more information returns of any single type. Electronic filing utilizes software that generates files in accordance with Publication 1220 specifications. Electronic filers benefit from the extended March 31, 2020, deadline for forms without box 7 reporting and do not need to submit Form 1096. The IRS FIRE system processes electronic submissions, and you receive acknowledgment of receipt and acceptance status.
Step 12: Apply Backup Withholding When Required
Withhold federal income tax at the backup withholding rate when required and report withheld amounts in box 4. Backup withholding applies when recipients fail to provide a TIN, give an incorrect TIN, or are notified by the IRS that they are subject to backup withholding. The backup withholding rate for 2019 is 24 percent. Report backup withholding on payments in boxes 1, 2, 3, 5, 6, 7 (except cash fish purchases), 8, 10, and 14. Also, report in box 4 any income tax withheld from Indian gaming profit payments to tribal members.
Step 13: Mark the FATCA Filing Requirement Checkbox if Applicable
Check the FATCA filing requirement box if you are a U.S. payer reporting on Form 1099-MISC as part of satisfying your chapter 4 account reporting requirement under FATCA. Also check this box if you are a Foreign Financial Institution reporting payments to a U.S. account pursuant to certain regulatory elections. The checkbox indicates you are fulfilling FATCA obligations through this information return filing. Recipients may have separate Form 8938 filing obligations based on their foreign financial assets.
Step 14: Maintain Proper Records
Retain copies of all Forms 1099-MISC and supporting documentation for at least three years from the filing due date. Keep records showing the nature and amount of each payment, dates of payment, recipient names and TINs, and copies of Forms W-9 or other TIN verification. Proper recordkeeping protects you during IRS examinations and helps you respond to recipient inquiries: Store Copy C and other file copies in an organized system that allows quick retrieval.
Step 15: Correct Errors Promptly
If you discover errors after filing, prepare corrected Forms 1099-MISC immediately. For paper corrections, check the CORRECTED box at the top of the form, but do not check the VOID box, as that prevents IRS scanning equipment from processing the correction. For electronic corrections, follow Publication 1220 procedures to submit corrected records. Furnish corrected statements to recipients clearly marked as "corrected" to distinguish them from original statements.
2019-Specific Regulatory and Instructional Changes
The January 31, 2020, due date for filing Copy A applies exclusively when box 7, nonemployee compensation, contains reportable payments. All other reporting without box 7 amounts uses the traditional February 28, 2020, paper deadline or March 31, 2020, electronic deadline. This accelerated deadline for Box 7 did not exist in prior years and represents a significant change that requires careful attention to filing deadlines.
The extended furnishment deadline of February 18, 2020, for Copy B applies when box 8 or box 14 contains reportable payments. The standard January 31, 2020, deadline applies to all other boxes. This represents a 2019 instructional clarification providing additional time for complex reporting situations involving substitute payments and attorney gross proceeds.
Section 409A reporting in boxes 15a and 15b follows specific rules for 2019. Box 15a reporting remains optional and tracks total deferrals under non-qualified plans. Box 15b captures only amounts currently taxable because the NQDC plan fails the section 409A safe harbor requirements. Recipients face substantial additional tax on box 15b amounts when filing Form 1040 or Form 1040NR, calculated as 20 percent of the quantity includible plus interest on tax underpayments.
The FATCA filing requirement checkbox serves an important compliance function for 2019. When marked, the payer satisfies Chapter 4 account reporting obligations under the Foreign Account Tax Compliance Act. This eliminates duplicative reporting requirements for certain foreign accounts while ensuring the proper sharing of information with the IRS.
Box 4, Federal Income Tax Withheld, encompasses both backup withholding and Indian gaming profit withholding for 2019. Backup withholding applies when Form W-9 requirements are not met or when the IRS mandates withholding. Publication 505 and Publication 15-A provide detailed guidance on backup withholding conditions, rates, and deposit requirements for amounts withheld throughout the year.
Payments to corporations generally do not require Form 1099-MISC reporting; however, important exceptions apply for 2019. You must report payments to corporations for medical and health care services in box 6, attorneys’ fees in box 7, gross proceeds to attorneys in box 14, substitute payments in box 8, and payments by federal executive agencies for services. The corporate exemption does not apply to these specific payment categories.
Filing Method Considerations
Paper filers must use official scannable forms ordered from the IRS or IRS-approved substitute forms that meet the specifications outlined in Publication 1179. Forms downloaded and printed from the IRS website often lack the required red dropout ink and are not in a scannable format, which can cause processing delays and potential penalties. Paper filers also must complete Form 1096 as a transmittal document and mail all forms together to the appropriate IRS processing center based on the form type and the filer’s location.
Electronic filers benefit from extended deadlines, immediate transmission confirmation, and elimination of Form 1096 requirements. Software must comply with Publication 1220 technical specifications and generate properly formatted files for IRS FIRE system processing. The IRS mandates electronic filing when you submit 250 or more information returns of any single type, though voluntary electronic filing is available for smaller volumes and provides processing advantages.
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This checklist is for educational purposes only and does not constitute tax or legal advice. Always review official IRS instructions and consult a qualified professional for guidance.
