In this episode of Information Return Intelligence, host Jason Dinesen is joined by Deborah Richardson, nationally recognized accounts payable consultant, speaker, and trainer, to break down a draft revision of Form W-9 that could have significant implications for vendor setup and 1099 compliance.

While the IRS has not yet finalized the form, the proposed change is more consequential than it may appear at first glance—particularly for individuals and sole proprietors.

🔍 The Key Proposed Change

Under the draft Form W-9, vendors classified as individuals or sole proprietors would be required to provide a Social Security number (SSN) rather than an Employer Identification Number (EIN).

Jason and Deborah explain:

Why this change likely targets single-member LLCs taxed as sole proprietors

How it could affect existing W-9s already on file

Why this may create real-world friction for AP departments—even if the rule itself is technically simple

🧠 What AP Departments Should Be Doing Now

Even though the form is still in draft status, this episode outlines practical steps AP teams should consider:

Don’t panic—the IRS has not finalized or announced an effective date

Bookmark the official IRS W-9 PDF, not just the webpage, to catch silent updates

Continue focusing on timely 1099 and 1042 reporting obligations

Ensure TIN matching and vendor master data accuracy are already solid

🔁 Re-soliciting W-9s: Will You Have To?

One of the most important discussions in the episode centers on whether AP teams may need to re-solicit W-9s from existing vendors who:

Are individuals or sole proprietors, and

Previously provided an EIN

Deborah and Jason discuss:

How system limitations may make identification difficult

Why this change could be different from prior W-9 revisions

The importance of consulting internal leadership and tax advisors before launching large-scale re-solicitation projects

🔐 Data Security Considerations

Because this change may increase the collection of SSNs, the episode also dives into data security best practices, including:

Why email is a high-risk method for collecting W-9s

Using secure email platforms, portals, or SharePoint-style solutions

Reducing unnecessary internal exposure to sensitive vendor data

The value of documented procedures for vendor setup and maintenance

🧾 A Case for Substitute W-9s

Deborah also explains why substitute W-9 / vendor setup forms can be especially valuable when IRS forms change—and what compliance requirements companies must meet when using them.

🎧 Final Takeaway

This episode reinforces a familiar reality in information reporting:

The IRS doesn’t always give clear guidance—and sometimes you have to make reasonable, well-documented decisions in the absence of it.

For AP professionals, preparation, process, and documentation remain the best defense.

Guest: Deborah Richardson
Accounts Payable Consultant, Speaker & Trainer
Host of Putting the AP in Happy

Host: Jason Dinesen
Information Return Intelligence

As 2025 comes to a close, this special year-end episode of Information Return Intelligence looks back at the most important developments in information return reporting—especially those affecting accounts payable and compliance teams.

We walk chronologically through the year, highlighting regulatory changes, IRS guidance, legislation, and draft forms that will shape reporting obligations in 2025 and beyond.

Key topics covered include:

• January regulations on digital and cloud transactions
  Final regulations clarified how digital transactions are classified (royalty, sale, lease, services, or know-how), while new rules on cloud computing—such as SaaS—generally treat these arrangements as services, with major implications for 1099-NEC and 1042 reporting.
• Sourcing challenges for cloud transactions
  Proposed sourcing rules introduced a three-factor formula for U.S. vs. foreign sourcing—an approach widely criticized as impractical for information return filers.
• IRS ruling on tribal payments
  A private letter ruling confirmed that Native American tribes are subject to Section 6041 reporting, including issuing Forms 1099 for prize winnings such as powwow contest awards.
• The FIRE system sunset timeline
  The IRS stated—in writing—that the FIRE system is expected to shut down in December 2026, leaving IRIS as the sole electronic filing platform.
• The “Big Beautiful Bill” and information reporting
  Major highlights include:
  • The long-awaited increase of the $600 reporting threshold to $2,000, effective in 2026 and indexed for inflation thereafter
  • Rollback of prior changes to Form 1099-K thresholds
  • New deductions for tips and overtime, with downstream reporting implications
• Sports gambling and Form 1042-S
  IRS guidance confirmed that sports gambling winnings paid to nonresident aliens are subject to Form 1042-S reporting and 30% withholding, absent treaty relief.
• Draft Form W-9 changes
  Draft versions released in September and December propose eliminating the ability for sole proprietors to provide an EIN instead of an SSN—a change still pending as of year-end.
• New reporting boxes for tips and overtime
  Draft 2026 versions of Forms 1099-NEC, 1099-MISC, and 1099-K include new boxes for tips and overtime, reflecting coordination challenges between IRS tax rules and Department of Labor standards.

This episode ties together the biggest themes of 2025 and sets the stage for what filers need to watch heading into 2026—particularly threshold changes, IRIS adoption, and evolving worker classification issues.

🎧 Listen now to get fully caught up before the new reporting year begins.

This week, we lead into Christmas on a lighter note. An animated cartoon Jason created, called "A 1099 Christmas Carol." If you want to see the video, head to our YouTube page. https://www.youtube.com/@InformationReturnIntelligence

Credits:

A 1099 Christmas Carol

Written by: Jason Dinesen

Animated by: Jason Dinesen in Runway (www.runwayml.com)

Music: Joy to the World (Instrumental) by Matthew L. Fisher – license purchased by Dinesen Media Ventures, LLC through Audiio (www.audiio.com)

Images for Animation: created in ChatGPT by Jason Dinesen

Voices:

· Roger Jackson: Jackson Dinesen

· Mr. Wiley, Ward Hussey, Roger’s father, IRIS: Jason Dinesen

· W-9: Tyler Dinesen

· 2K: Tracy Dinesen