Comments to the IRS Counsel: Impact of Sec. 6041 Changes

The Patient Protection and Affordable Care Act of 2010 (PL 111-148) enacted a dramatic expansion of transactional reporting. Under the enacted changes, all payments made in a trade or business for goods and/or services whose aggregate value exceeds US$ 600.00 must be reported whether the recipient is an individual or a corporation. Previously, only services provided by proprietorships had been subject to a reporting on Form 1099-MISC. Previously, I had commented on the impact of these changes in Ruminations – An IT Blog. Recently, the Counsel to the Commissioner of the United States Internal Revenue Service solicited comments from those affected. I prepared a summary of these comments in an e-mail to the Service's counsel.

My summary included the following:

A repeal of the reporting provision would be best. Such a repeal has been introduced, but has not been enacted by Congress. In the absence of repeal, the above measures would significantly reduce the adverse impact of the required reporting.


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