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Form 1099-C: Cancellation of Debt Income

November 12th, 2014 No comments

Taxpayers who have any type of debt cancellation or forgiveness will have to report that amount as taxable income.  The lender will file this form if there was more than $600 worth of cancelled debt for the tax year.  There are a few instances where this type of debt cancellation can occur, including:

 

  • A negotiated settlement of a debt that is for less than the original amount owed. This can occur frequently where debt negotiation is used as a substitute for bankruptcy.  However, the tax on the cancelled portion of the debt can be significant where debts are negotiated for a small percentage of the original loan.
  • Non-payment of a debt for at least 3 years and no collection attempts for 12 months. This seems to operate as a “passive cancellation” if the creditor has given up collection efforts.
  • A home in foreclosure there is a deficiency that the homeowner does not have to pay

 

The only way to avoid paying taxes on these amounts is if you can show that you are insolvent (debts exceed assets) or you have a mortgage forgiven that is covered by a legal exclusion.  Also, debts that are dissolved in bankruptcy don’t have to be claimed as income, and the creditor should not issue a 1099-C.

 

The form itself is fairly simple among the 1099 informational forms.  The left hand side of the form has boxes for both creditor and debtor information, including name, addresses and tax identification numbers.  The right hand side has the following boxes:

 

Box 1 :  Date of the identifiable event e.g. when the debt was cancelled.

 

Box 2 :  Amount of the cancelled debt

 

Box 3 :  If interest was included in the cancelled amount, then it would be listed here

 

Box 4 :  Description of the original debt such as credit card, mortgage, etc

 

Box 5 :  Contains a checkbox for the situation where the debtor was personally liable for repayment of the debt

 

Box 6 : The code for the identifiable event (reason the debt was cancelled such as debt relief, foreclosure, etc.)

 

Box 7 : Fair market value of property such as real estate to determine deficiency and calculate amounts forgiven.

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Amending Form 1099 After It Has Been Filed

October 27th, 2014 No comments

Not every Form 1099 submitted to the IRS is correct, and there are many types of errors that can creep into this form, especially if you issue many 1099s each year.  There are different processes for correcting and amending a 1099, depending on whether you are a recipient or the one who filed the incorrect form.  Form 1099 may be filed by paper or electronically.

Steps for Recipients of an Incorrect Form 1099

Most 1099s deal with independent contractor income, using Form 1099-MISC.  If you receive multiple 1099s there is a chance of errors, so the first step is to check the 1099 as soon as your receive it against your own records.  Since February 2nd is the deadline in 2015 to receive a 1099, you will have at least a month until the issuer must submit the form to the IRS on March 2nd , or even later on March 31st for those who file electronically.  Of course, some issuers may send both at the same time, but if you check the form as soon as you receive it you should be able to contact them in time to have a new, correct form sent to you.

Even if the form has been sent to the IRS, you can request a “corrected” form from the issuer.  The “corrected” box will inform the IRS that this is a new version of the one already sent.  If the issuer wont send you a new form, then you will have to handle the incorrect form yourself, and explain the discrepancy or mistake to the IRS in an attached statement.

Steps for Issuers of an Incorrect 1099

The steps for correcting a 1099 that you may have issued depend on the type of error.  The most common type of error will be incorrect money amounts listed on the form, and in this case the remedy is to simply prepare a new 1099 with the box marked “corrected”.   Correct the information and file the new form.  This is the same process to use if the name or address were entered incorrectly.

Forms that have errors in recipient tax identification numbers, or incorrect name AND address have a slightly different process for correction.  You first prepare a new 1099 marked “corrected” with the exact same information as the original return, but enter zero for payment amount.  This alerts the IRS that there was a problem.  Then prepare a new form with the correct information and submit it as though it is an original, without marking the “corrected” box.  This identifies the second form as the correct version for the IRS.

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Form 1099-MISC:  Payments to Independent Contractors

October 27th, 2014 No comments

One of the most frequent uses of Form 1099-MISC is to report payments for services to non-employees or independent contractors.  Those payments are listed in box 7 of the 1099-MISC for annual amounts of $600 or more.  It is the payer who makes this determination of the work relationship, and there are tests the IRS uses to classify employees vs. independent contractor.  The most important of these is that the IRS presumes that work performed is part of an employee relationship, and the payer may have to demonstrate why they are treating the worker as an independent contractor.

Employee vs. Independent Contractor Relationships

According to the IRS instructions for 1099-MISC, the basic tests used to define the employee relationship center around behavioral control, financial control and relationship of the parties.  Behavioral control means that a worker receives extensive instructions on how to perform the work, as well as specific training.  Financial control is determined by the worker’s own investment in the work, and the potential to realize a profit or loss.  In other words, if their services are part of a broader work scheme that they own and operate, then they may be contractors and not employees.  Finally, the relationship between the parties may be ultimately determined by the nature of the contract that is used, and evidence of control and employee status contained in the contract terms.

The Process of Determining Status

Form SS-8 is used by workers who request to have their work status determined by the IRS, if the worker feels that they are actually in an employment relationship.  Some workers may feel unfairly excluded from the employee status, and the benefits that go along with it.  The form has many questions that pertain to the issues of control and the nature of the work relationship, and as mentioned the business has to overcome the presumption that the worker is an employee.

The advantage for a business in paying independent contractors is that they can avoid paying the employer portion of Medicaid and social security for the worker.  If the worker is self-employed, they pay the entire amount as self-employment tax.  Also, independent contractors are not entitled to any benefits such as health or disability insurance, so a business can realize savings in this area as well.

However the IRS does scrutinize this relationship and will make a determination either on its own as part of an audit or at the request of the worker.  Any business that claims workers are independent contractors would be well served to have a personal services contract that clearly defines the relationship.

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Tax Year 2014: What’s new for the 1042-S and 1099 forms?

August 29th, 2014 No comments

All of the 1097-BTC, 1098, 1099, 3921, 3922, 5498 and W-2G forms changed from tax year 2013 to tax year 2014.  Instead of saying

City or town, province or state, country, and ZIP or foreign postal code

All of the forms say in tax year 2014

City or town, state or province, country, and ZIP or foreign postal code

Swapping the word state with province is a minor change, but a change nonetheless on all of the information returns for tax year 2014.

Other change made to this year’s revenue procedure are as follows:

  • Form 1099-B has been completely revised for new reporting requirements. Additional boxes have been added.  IRS Form 1099-B looks completely different from tax year 2013.
  • Form 1099-H. This form has been made obsolete.  The Health Care Tax Credit expired December 31, 2013.
  • Form 1099-INT. Boxes 10 through 13 have been renumbered boxes 12 through 15. New box 10 is used to report market discount. New box 11 is used to report bond premium.
  • Form 1099-K. Box 1 has been divided. Box 1a continues to report gross amount of payment card/third party network transactions. Box 1b reports the amount of transactions for which no card was presented. The 2nd TIN not. box was added to Copies A and C. The account number box has been shorted to accommodate the 2nd TIN not. box.
  • Form 5498. Boxes 15a and 15b have been added for reporting the FMV of certain specified assets held in IRAs.
  • Form 1042-S is completely new to accommodate Chapter 4 FATCA requirements.

Our 1099 software has been modified to include all of these changes for tax year 2014.

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All About Form 1099-A and Form 1099-C

July 12th, 2014 No comments

Individuals or business entities who borrow money from a lender whether it be a lending institution for the purchase of a property may be required by the lending entity to secure the loan by the property being purchased. Should an individual then go ahead to transfer an interest in the secured property to the lending entity as the case would be in a foreclosure, or should an individual abandon the property, he or she may be required to treat the transfer or the abandonment as an actual sale of the property in question. Should the lending entity acquire an interest in the secured property or have a reason to know that you abandoned the property, the lending entity is required to send you a Form 1099-A for the acquisition or the abandonment of a secured property.

When an individual borrows money, he or she is not required to include the proceeds of the loan in gross income. This is because the borrower has an inherent obligation to repay the lender at a later date. Should that obligation be cancelled, the borrower is required to include this cancelled debt in gross income. When a commercial lender cancels a debt, the lending body will disburse a Form1099-C with regard to the cancellation of debt. This is the official method of reporting the debt cancellation.

The form 1099-A reports the principal amount owed to the lender as well as the fair market value of the property secured. This is then used by the debtor in determining whether there is a gain or loss in the property disposition. The form 1099-C reports the cancelled debt by the lender. The Form 1099-C may be used singly, if the interest of the lender in the secured debt or the abandonment of the property by the debtor as well as the cancellation of the debt all happen within the same calendar year. Should the borrower receive Form 1099-C or Form 1099-A with incorrect information, one should contact the lender in order for him to make the necessary corrections. Failure to do this could lead to penalties being imposed on your for providing the incorrect information or you could end up being short changed in the long run.

There are some circumstances that may call for the cancellation of debt income wholly or partially.  One such case is whereby you have a debt income cancellation on ones principal residence. Here one may be allowed to exclude the whole amount or part of the amount that is cancelled from your income. This is provided for expressly in the Mortgage Forgiveness Debt Relief Act of 2007.

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Understanding IRS Form 5498

July 12th, 2014 No comments

The federal government has an interest in making sure people sock away money for retirement, so many contributions you make to certain individual retirement arrangement (IRA) accounts are tax-deductible until you finally pull that money out once you are in your seventies.  Of course, there is a limit on how much you can deduct every year, but it can add up to a pretty tidy deduction, and when it comes to your tax bill, every bit helps.

If you are saving for retirement (and you should be, no matter what age you are) there are some things you need to know about IRS Form 5498.

  1. It’s not your responsibility to file it with the government.  Whoever acts as the trustee or the IRA issuer is required by law to file this form with the IRS.  If you receive a copy from them, it’s only for your files.
  2. Rolling over or converting assets from a different retirement plan into an IRA isn’t tax deductible.  However, they are still treated as “contributions” by the IRS, so they go in a separate box on the form.  However, there are other rules covering special cases like rollovers between traditional IRAs and specialized accounts like SEP IRAs and Roth IRAs.  Check with the administrator of your plan if you have questions.
  3. If you are married or have two retirement plans, you might not be able to get the full deduction.  If you have a tax-advantaged retirement account aside from your IRA, or your spouse is also contributing to their own IRA, you may bump up against the maximum contribution amount set by the IRS.
  4. You can deduct current-year contributions from prior-year tax returns.  This is a great thing – if a little confusing.  Essentially, you can claim all of your contributions from 2014 on your 2013 tax return through April 15th.  This is why you may not receive a copy of your form 5498 from your plan administrator until May 31st, the legal deadline.
  5. You can’t deduct contributions to Roth IRAs, SIMPLE IRAs or SEP plans.  There are a variety of reasons for this, most of them involving the time at which you pay the taxes (Uncle Sam will always get his money, no matter what) but if you are not contributing to a traditional IRA, you can’t deduct your contributions on a tax return.

There you have them – five facts everyone needs to know about IRS Form 5498.  If it’s all still a whirlwind, don’t worry – there is help available.  You can use specialized software to help with your Form 5498 from a website like 1099fire.com, which also has a bunch of other services available no matter what form or part of your taxes you are struggling with.  It is always better to be safe than sorry when it comes to the IRS – so if you have questions or are unsure about anything, don’t hesitate to seek out professional help!

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Brokered and Bartered: Form 1099-B

July 12th, 2014 No comments

Brokers use IRS Form 1099-B, Proceeds From Broker and Barter Exchange Transactions, to report the proceeds from the sale, transfer or exchange of securities, including:

  • Stocks and funds
  • Bonds and other debt instruments
  • Futures contracts
  • Options
  • Commodities
  • Foreign currency contracts
  • Fixed investment trusts
  • Short sales
  • Partnership shares

The broker must file a multi-part Form 1099-B for each customer who has sold securities for cash, who bartered property or services, or has received stock or cash because of foreign merger or acquisition.

You Just Might Be a Broker If….

The IRS considers you a broker if you are in the business of transacting sales of securities offered by others. You can be an individual, American or foreign, a governmental unit or a company. You’re also a broker if you issue and retire debt obligations or are a company that regularly redeems its own stock. However, you’re off the hook if you manage a farm for someone else, your company buys only odd-lot shares from its stockholders on an infrequent basis, or you’re an international corporation that redeems its own debt. You may not have to fill out Form 1099-B in connection with the sale of shares arising from incentive stock options that are exercised on the same day as the shares are sold.

You also fill out Form 1099-B if you are a barter exchange, which is a person — or an organization that has a set of members — who jointly trades or barters property/services. This doesn’t include the exchange of information for noncommercial purposes. You don’t have to file if you do less than 100 transactions a year, if you’re an exempt foreigner, or if the transactions have a fair market value under $1.

The third category of transactions that trigger the need to file Form 1099-B is when a customer receives property, cash or stock from a corporation that must recognize a gain because of a takeover by a foreign company. These types of transactions must also be reported on Form 8806. If proceeds are paid in a foreign currency, you must report the amount in U.S. dollars using the spot exchange rate on or around the date the money is received.

Other filing exceptions are granted for a variety of reasons, including:

  • Sales by charities, IRAs, health savings accounts, federal and state governments, and C corporations
  • Sales by dealers, custodians and trustees
  • Sale at the issue price of shares of certain regulated investment companies
  • Sale of certain types and amounts of precious metals (not metal contracts)
  • Sales of foreign currencies (not currency contracts)
  • Debt-related transactions involving payments on savings bonds, CDs, retirement of OID securities issued prior to 2014, and callable demand obligations redeemed at par and issued before 2014
  • Fractional shares worth less than $20
  • Spot and forward sale of certain agricultural commodities
  • Sales for exempt foreign customers

Filling Out the Form

Form 1099-B had a face-lift in 2014 so that it coordinates with Form 8949, Sales and Other Dispositions of Capital Assets, which the customer who receives a copy of 1099-B must file. The broker enters a code on the 1099-B matching the code from the applicable checkbox on Form 8948. Those codes are:

  • A: Short-term transactions with reportable basis
  • B: Short-term transaction not reported to the IRS
  • D: Long-term transactions with reportable basis
  • E: Long-term transaction not reported to the IRS
  • X: Unknown holding period

The form requires the usually identifying information for the broker and the customer, including names, tax identification numbers and addresses. The form also records the customer’s account number and the CUSIP number of the security.

The required data for the sales transaction includes:

  • Property description
  • Dates acquired and sold
  • Proceeds
  • Cost basis and adjustments, such as market discounts and wash sales
  • Code indicating a wash sale, the sale of a collectible, or a market discount
  • Short- or long-term gain/loss
  • Indication of whether the basis was reported to the IRS, and whether the gross or net proceeds were reported
  • Federal income tax withheld
  • Whether the security is non-covered, meaning the cost basis doesn’t have to be reported. This applies to certain complex debt instruments until 2016.
  • Disallowed losses
  • Realized profit/loss on closed contracts
  • Unrealized profit/loss on open contracts
  • Aggregate profit/loss on contracts
  • Gross amount bartered
  • State information, including state tax withheld

Filing Requirements

Form 1099-B is multi-part:

  • Copy A goes to the IRS
  • Copy 1 goes to a state’s tax department
  • Copy B goes to the customer
  • Copy 2 goes to the customer, who attaches it to a state tax return
  • Copy C is the broker’s file copy

Brokers must send Copy B and Copy 2 to the customer by February 15. Paper versions of Copy A go to the IRS at the end of February, but electronic versions don’t have to go until the end of March. If the customer is a nonresident alien and you’ve withheld federal income tax, you must also file Form 1042-S.

Accompany your filings of Form 1099-B with the Form 1096, Annual Summary and Transmittal of U.S. Information Returns.

If you miss your filing deadlines, the IRS can assess penalties that can’t exceed $1.5 million per tax year. Brokers can relieve the stress of filing the very detailed form by purchasing Form 1099-B software to load the data and print/mail or electronically transmit the forms. An even easier solution is to use a service bureau to do the preparation and filing for you.

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A Is for Abandonment

July 8th, 2014 No comments

Mortgage companies, bond issuers and other lenders sometimes must deal with deadbeat borrowers and abandoned properties. The mortgage crisis of 2007-08 caused many homeowners to lose their homes, a condition that is only slowly getting better. For mortgage lenders and those who make secured loans, times have been tough and have led to the assumption of properties that served as collateral. When this occurs, lenders must send copies of Form 1099-A, Acquisition or Abandonment of Secured Property, to the IRS and to the borrower.

Secured Property

The property covered by Form 1099-A is any real, tangible or intangible property that served to secure a loan. A couple of exceptions don’t require filing of the form:

1)    Property is located outside of the United States and the borrower is an exempt foreign person.

2)    The property is tangible personal property, such as a car, that the borrower didn’t use for business or as an investment.

Sometimes, multiple owners — investment pools, trusts, government units, subsequent holders, etc. — share a loan. In this case, a responsible person, such as a trustee or owner of record, files Form 1099-A on behalf of all the co-lenders.

Do not confuse multiple owners of a single loan with multiple lenders that have extended different loans secured by the same property. For example, if a company mortgages a factory to three different lenders and then defaults on a payment, one or more of the lenders may foreclose on the property. If this happens, all the lenders must file Form 1099-A, because the value of their claims on the collateral is reduced.

Abandoned and Acquired Property

Some borrowers simply walk away from the property they’ve used to secure a loan on which they can no longer make the payments. This is abandoned property and lenders must file Form 1099-A if they become aware of the fact. The IRS expects you to know, or have reason to know, when a borrower abandons a secured property, if the information was available through a reasonable inquiry. The reporting requirement arises no later than three months after learning of the abandonment or upon foreclosing on or selling the property.

Acquisition occurs at the earlier of the date you took title or the date upon which you received the burdens and benefits of ownership. Sometimes, the borrower may object, and if there is an objection period, your acquisition dates from the end of that period. If you buy a secured property sold to satisfy a debt, the acquisition date is the date of sale or the date the borrower’s right to redeem the debt expires, whichever occurs later.

Filling Out Form 1099-A

Here is the information the lender must provide when filling out Form 1099-A:

  • Identifying information of lender and borrower, including federal identification numbers
  • Account number
  • Date of lender’s acquisition or knowledge of abandonment
  • Balance of principal outstanding, not including accrued interest or foreclosure costs
  • The property’s fair market value, which can be the gross foreclosure bid price or the appraised value
  • An indication whether the borrower was personally liable for repaying the debt
  • Property description, include the address of real property, the section, lot and block if necessary, or the type, make and model of personal property such as a car, office equipment or abandoned crops that secure a Commodity Credit Corporation loan.

Filing Rules

You must accompany Form 1099-A with a copy of Form 1096, Annual Summary and Transmittal of U.S. Information. If you forgive all or part of the loan, file Form 1099-C, Cancellation of Debt, instead of filing Form 1099-A. File paper copies with the IRS by the end of February and electronic copies by the end of March. File a copy with the borrower by the end of January. To save time and resources, you can use a provider of mail house solutions to print, fold, stuff and mail your returns. If you are a bank or financial institution with many copies of Form 1099-A to complete, consider buying 1099-A software that allows you to enter the information and then create the file, which you can print off or transmit electronically. You can also hire a service provider to take all the work off your hands. The IRS assesses penalties for failure to file Form 1099-A, up to $1.5 million per tax year.

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Reporting the Initial Transfer of Incentive Stock using Form 3922

July 7th, 2014 No comments

Corporations often offer incentive stock options to some set of employees as a bonus or reward for work. As we described in our discussion of Form 3921, these incentive stock options (ISOs) are valuable because they allow employees to purchase company stock at a discount, as long as certain tenure conditions are met. Once an employee exercises an ISO, she might want to sell the stock or transfer the shares out of the company and into her brokerage account. When this occurs, the corporation must file Form 3922, Transfer of Stock Acquired Through an Employee Stock Purchase Plan Under Section 423(c).

Requirement to File

The corporation issuing the ISOs must report on Form 3922 the transfer of the stock resulting from the option exercise if certain conditions are met:

  1. Section 423(c) of the tax regulations governs the ISOs.
  2. The employee sells/gifts the shares or transfers them to an account outside the company.
  3. The exercise price of the ISO is less than 100 percent of the stock’s value on the grant date, or the price is indeterminate on that date.
  4. The shares must have serial numbers, and physical certificates must have a unique color.
  5. The employee has filed a W-2 Form and is not a nonresident alien.
  6. The issuer of the stock is the stock’s corporation, a related corporation, an agent of the corporation, a third party such as a brokerage firm that is distributing the stock and any party who controls the payments to employees of the corporation.

The corporation must issue a copy of Form 3922 to the employee by January 31 and to the IRS by February 28 if filing paper copies or March 31 for electronic filings. Note that no tax is due from the transfer to an outside broker if the employee remains the beneficial owner. If sold, the employee must report the sale as a gain or loss.

Filling Out the Form

Enter the following information onto Form 3922:

  • Corporation identification
  • Employee identification
  • Account number
  • Date the option was granted
  • Date the option was exercised
  • Fair market value of shares on grant date and on exercise date
  • Exercise price
  • Number of shares transferred
  • Date that legal title was transferred
  • The exercise price as if the options were exercised on the grant date

Filing Form 3922

A large company that grants many ISOs to many employees faces the huge task of issuing copies of Form 3922 for all option-related stock transfers. The company can choose to completely outsource the job or to purchase Form 3922 software to ease the task. Although an employer could file using paper forms, electronic filing is required when the number of forms exceeds 250.

Failing to file is not an option, because the IRS extracts penalties for missing, late or incorrect filings. Penalties begin at $30 per form, escalate to $100, and the aggregate fine can reach as high as $1.5 million a year.

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IRS Form 1096

July 7th, 2014 No comments

IRS Form 1096, Annual Summary and Transmittal of U.S. Information Returns, is somewhat unique, because it’s a form about other forms. Its purpose is to serve as a cover form when you have to file certain other tax forms, usually ones related to your status as an employer or trustee/custodian. You only use Form 1096 when filing by paper — there is a different procedure for electronic filing.

Form Design

Form 1096 has many boxes. Start by filling in the following identifying information:

  • Filer’s name
  • Street address
  • City, State, Zip
  • Name of person to contact
  • Telephone number
  • Email address
  • Fax number
  • Employer identification number
  • Social Security number
  • Total number of forms

Next, you’ll report tax information:

  • Federal income tax withheld
  • Total amount reported with this copy of Form 1096
  • An indication as to whether you are filing your final return

Pick a Box

What follows on Form 1096 is an array of 28 boxes, each one with a label and checkbox. Each box represents a different IRS form. Now here’s the kicker:  YOU ONLY CHECK ONE BOX FOR EACH COPY OF FORM 1096. Let that sink in. Theoretically, you might have to file 28 different copies of Form 1096, each with a different box checked, for each employee or client. That would be highly unusual, of course, but realistically you might have to fill out several forms per person.

After checking the appropriate box, you transfer the total amount from the indicated box on the other IRS form to the Form 1096 box for the total amount reported by this 1096 form. The following is the honor roll of forms and boxes:

FORM BOX WITH TOTAL AMOUNT
Form W-2G Box 1
Form 1097-BTC Box 1
Form 1098 Boxes 1 and 2
Form 1098-C Box 4c
Form 1098-E Box 1
Form 1098-T None
Form 1099-A None
Form 1099-B Boxes 1d and 13
Form 1099-C Box 2
Form 1099-CAP Box 2
Form 1099-DIV Boxes 1a, 2a, 3, 8, 9, and 10
Form 1099-G None
Form 1099-H Box 1
Form 1099-INT Boxes 1, 3, 8, 10, and 11
Form 1099-K Box 1a
Form 1099-LTC Boxes 1 and 2
Form 1099-MISC Boxes 1, 2, 3, 5, 6, 7, 8, 10, 13, and 14
Form 1099-OID Boxes 1, 2, 5, 6, and 8
Form 1099-PATR Boxes 1, 2, 3, and 5
Form 1099-Q Box 1
Form 1099-R Box 1
Form 1099-S Box 2
Form 1099-SA Box 1
Form 3921 Boxes 3 and 4
Form 3922 Boxes 3, 4, and 5
Form 5498 Boxes 1, 2, 3, 4, 5, 8, 9, 10, 12b, 13a, and 14a
Form 5498-ESA Boxes 1 a
Form 5498-SA Box 1

So, for instance, if you had to fill out a copy of Form 1099-R for each of your clients, you’d check the box for that form and then transfer the amount from Box 1 of 1099-R to Form 1096. If your were required to file Form 1099-INT for those same, or different, clients, you would need to file additional copies of Form 1096, one per client, containing the appropriate checkmark and the total from the client’s Form 1099-INT boxes 1, 3, 8, 10, and 11. If this seems like a huge hassle, well, it is.

Filing Rules

You must file all copies of Form 1096 by the end of February. However, the due date for filing a Form 1096 that accompanies Form 5498 is June 1. If you fail to file in a timely manner, you might have to pay fines. If you file electronically using a service provider or software, make sure that the provider or software automatically prepares and transmits Form 1096 on your behalf. If you are filing 250 or more copies of Form 1096, you must file electronically.

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