Does the IRS allow separate 1099Qs to be submitted by two different vendors?

by Amy M. Swartzfager, CPA | Sep 07, 2018

I work for a company that provides case management software for 529 prepaid plans. We are currently taking on a new client, and its current vendor has stated they will generate 1099Qs for January to September of this year, and we would generate them for October to December of this year. Does the IRS permit two 1099Qs for the same plan?

Per the IRS’s 2018 General Instructions for Certain Information Returns, predecessor and successor business entities can each file their own 1099s or come to an agreement where one of the entities assumes the responsibility for filing combined information from both entities on one 1099. Therefore, it is acceptable to file two 1099Qs for the same plan.

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Answered by: Amy M. Swartzfager, CPA, is a senior tax analyst with API Technologies Corporation in Fairview, Pa. 

The responses are based on the limited information provided by the questioner and apply the laws and regulations at the time of posting. Other options could arise as rules and regulations may change over time, including but not limited to the passage of the Tax Cuts and Jobs Act of 2017. They are intended to provide general information, not specific accounting or tax advice; they are not intended or written to be used and cannot be used for the purpose of avoiding or evading taxes or penalties under the IRS code or regulations. Views expressed do not imply an opinion of the PICPA, its officers, directors, employees, or members.
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