|INFORMATIONAL CIRCULAR NO. 11-A-004|
|DATE:||October 14, 2010|
|SUBJECT:||IRS 1099 Reporting|
|EFFECTIVE DATE:||November 15, 2010.|
IRS 1099 Miscellaneous Reporting – revocation of exceptions
The Department of Administration is responsible for issuing IRS 1099 forms for all agencies so that we can report as a single entity. While a single payment may not exceed the reporting threshold, we are required to aggregate all payments and report if the total payments exceed the IRS reporting threshold. In the past a limited number of exceptions have been granted to not collect recipient data for de minimis payments.
We have reviewed this exception process with our agency attorney. We have been advised there should not be any exception from collecting 1099 data regardless of payment amount. Any single payment when added to all other agency payments could result in the vendor’s payments exceeding the reporting threshold, no matter how small the individual payment. Therefore, effective November 15, 2010, all exceptions from collecting and reporting 1099 data are revoked.