In this week’s What’s New episode of Information Return Intelligence, Jason Dinesen provides a concise mid-January update as the 1099 filing season gets underway. With electronic filing officially open and few last-minute surprises, this episode focuses on the key system and compliance issues filers should be aware of right now.

Key topics covered:

• 1099 e-Filing is Open
  • Electronic filing opened January 6.
  • Both FIRE and IRIS systems are live for the season.
• IRIS Expansion: Form 1042 Now Supported
  • IRIS can now accept Form 1042 (summary form) for the first time.
  • In prior years, IRIS could not accommodate this form.
• 1099-DA (Digital Asset Reporting)
  • If you are required to file Form 1099-DA, it must be submitted through IRIS only.
  • FIRE does not accept this form.
  • This typically applies only to certain brokerages and digital asset platforms.
• Important Reminder on Form 1042 (No “S”)
  • Form 1042 is subject to the e-file mandate.
  • It does not go through IRIS or FIRE.
  • Instead, it must be e-filed through the IRS MF (Mainframe) system.
  • Not all filing vendors support MF, so filers should confirm capabilities now.
  • No IRS paper-filing exception has been issued yet for 2025 (as of recording), though the form is not due until March 15.
• Publication 1099 (2026 Version) Signals FIRE’s Future
  • The IRS reiterates its plan to shut down the FIRE system by the end of 2026.
  • FIRE is mentioned only three times in the publication—all in the context of its shutdown.
  • IRIS is referenced 26 times, underscoring the IRS’s clear long-term direction.

Bottom line:

This is a relatively quiet “What’s New” period—which is good news. Filers can focus on getting forms submitted while keeping an eye on:

• Form 1042 e-filing logistics, and
• The ongoing transition away from FIRE toward IRIS.

🎧 Tune in next week for the next episode of Information Return Intelligence.

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

Today’s episode breaks down the fast-changing world of electronic filing for information returns — including major updates to FIRE, IRIS, and Form 1042/1042-S e-filing.

We cover:

🔹 The 10-form e-file threshold under the Taxpayer First Act
🔹 How W-2s fit into the e-file mandate (and why it’s not an “IRS rule”)
🔹 The scheduled shutdown of the FIRE system in December 2026
🔹 What that shutdown really means for the 2025 filing season
🔹 When and how to transition to IRIS
🔹 Limitations inside IRIS — including the 100-form upload cap
🔹 New ability to file Form 1042-S on IRIS
🔹 The ongoing Form 1042 problem (Modernized e-File) and how to handle it
🔹 Whether it makes sense to file through IRIS yourself or use a vendor
🔹 Why many filers partner with third-party providers like Avalara

If you deal with 1099s, 1042-S, W-9s, or electronic filing, this episode gives you the latest developments and practical steps to prepare for the coming changes.

🎙 Hosted by Jason Dinesen — “The 1099 Guy”
Fast, clear, practical intelligence for AP, payroll, and information-reporting pros.

In this episode, Jason breaks down one of the trickiest parts of compliance: state 1099 filing rules. Every state has its own requirements — and some of them will surprise you. (Looking at you, New York and Illinois!)

What You’ll Learn

• Why the state boxes on a 1099 don’t fulfill your state filing obligations
• How to determine which states you need to file in
• Why contractor location (and where the work is performed) matters
• How state backup withholding rules differ — especially California’s
• Why some states only require 1099s if you did state-level backup withholding
• How federal threshold changes (like the move to $2,000) may not match state rules
• Tips for keeping up with changing state portals, thresholds, and requirements
• A surprising trivia fact about two income-tax states with no 1099-NEC or 1099-MISC filing requirements

Referenced Resources

• IRS Publication 1220 (Combined Federal/State Filing Program chart)

About This Podcast

Information Return Intelligence is your weekly briefing on the constantly shifting world of information return compliance — from 1099-NEC to 1042-S and beyond. Short, fast-moving, and packed with practical insights.

In this episode of Information Return Intelligence, Jason revisits last week’s big topic: the new overtime deduction created by the One Big Beautiful Bill (OBBB). After initially believing there was no scenario where qualifying FLSA overtime could ever appear on a 1099… Jason discovered there is a rare situation where it actually can.

Join Jason as he breaks down:

• What counts as “qualifying overtime” under the OBBB
• Why Section 7 of the FLSA is the key to the deduction
• Why most overtime won’t qualify
• Why overtime is almost always reported on a W-2
• And how — in extremely unusual cases — it might legitimately show up on a 1099

Using IRS Notice 2025-69, Jason explains how a worker can be an employee under the Fair Labor Standards Act (DOL’s economic-realities test) while still being treated as a contractor for tax purposes (IRS three-factor test).

It’s rare. Think unicorn rare.
But it’s not impossible — and if it happens, employers need to know exactly why.

If you deal with 1099s, W-2s, worker classification, or compliance in general, this episode is a must-listen.

The IRS has issued new guidance on reporting tips and overtime, and while these topics usually live in the W-2 world, they now have implications for 1099 filers as well.

In this episode, Jason Dinesen — The 1099 Guy — explains how the Big Beautiful Bill created a new personal tax deduction for qualifying tips and qualifying overtime, and how upcoming changes to Form 1099-NEC and 1099-MISC will reflect this. Jason also breaks down the difference between voluntary and non-voluntary tips, why most overtime won’t qualify for contractors, and what AP and payroll teams need to track — even though processing the payments themselves won’t change.

You’ll learn:

• The new tip & overtime deduction created by recent legislation
• What counts as a qualifying tip (and what doesn’t)
• Why qualifying overtime rarely applies to contractors
• How upcoming 2026 1099 forms will include new boxes
• What issuers must track for future reporting

Information Return Intelligence delivers weekly insights to help accounting and finance pros stay compliant with 1099, 1042-S, W-9, and related reporting rules.

🎙️ Hosted by Jason Dinesen, EA — The 1099 Guy