Understanding the evolving 1099-K reporting landscape across federal and state jurisdictions
On November 26, 2024, the IRS issued Notice 2024-85, introducing a phased approach to the reduced Form 1099-K reporting thresholds for Third-Party Settlement Organizations (TPSOs). These updates come amid ongoing complexities around federal and state reporting requirements. Here's what you need to know about the latest developments, and see the press release for more information.
New Federal Threshold Timeline
The IRS has announced the following transitional thresholds for Form 1099-K reporting:
Compliance Notes
Impact on Small Sellers and Casual Transactions
The reduced thresholds—especially the $600 level—have raised concerns about improper reporting of non-taxable transactions. For instance, casual sellers or individuals reimbursing friends may be mistakenly flagged, resulting in unnecessary IRS scrutiny.
State-level Reporting Challenges
Many states have already adopted the $600 threshold. This creates added complexity for TPSOs and businesses operating across multiple jurisdictions, as state requirements may differ from federal thresholds. Some states may adhere strictly to the statutory $600 level, regardless of IRS penalty relief.
TPSOs need to:
For taxpayers, the evolving thresholds mean increased vigilance in understanding what income is taxable, especially when engaging in activities like selling used goods or collecting reimbursements.
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