On July 26, APA offered several recommendations to the IRS in reference to its request for comments on proposed regulations for filing information returns electronically, including increased outreach, additional time to comply, and improved IRS electronic filing options.
The proposed regulations would require that all information returns, regardless of type, be taken into account to determine whether a business meets the 250-return threshold that determines whether information returns must be filed electronically (83 F.R. 24948, 5-31-18).The information returns subject to the regulation include Forms 1042-S, 1094 series, 1095-B, 1095-C, 1098, 1098-E, 1098-T, 1099 series, 5498, 8027, and W-2 series. If finalized, the regulations would increase the number of information returns required to be filed electronically.
The problem in aggregating the forms for many employers is that different departments, such as payroll and accounts payable, manage the various forms. Each department may have separate electronic systems and electronic communication capabilities, which makes the number of forms harder to tally. In addition to articles in the media on the new requirements, APA recommended that the IRS send letters to businesses that would otherwise have met the aggregated threshold based on past filings. APA also asked the IRS to push the effective date back to January 1, 2020 (from January 1, 2019), and to create a free-file option for Form 1099-MISC.
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