I noticed that there is a FATCA box on the 2015 Form 1099. All of the vendors we issue 1099s to are domestic vendors and receive non-employee compensation. When would this box be checked?

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The FATCA filing box is for FATCA-related reporting, per the Instructions for Form 1099-MISC, page 4. In trying to understand FATCA, it’s helpful to remember the point of FATCA is to uncover non-U.S. financial assets of U.S. persons. U.S. payors must withhold on payments to foreign financial institutions (FFIs) and nonfinancial foreign entities (NFFEs) if those entities have not agreed to provide the IRS with information on accounts of U.S. persons.

This does not impact your reporting of payments made to non-employee U.S. vendors for services. The usual Chapter 3 reporting and withholding rules apply.

Also see FATCA supplement to the 2014 General Instructions for Certain Information Returns reporting on Forms 1099.

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