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Compliance

Understanding U.S. Compliance Changes: Form 1099-K, ERC, and PTIN in the One, Big, Beautiful Bill

A wave of compliance updates under the One, Big, Beautiful Bill affects third-party payment thresholds, tax preparer ID rules, and recovery of credits—what businesses and tax professionals need to prioritize now.

By NomadicTax Research Team · 5-8 min read

What’s Changed Under the One, Big, Beautiful Bill (OBBB)

Since enactment, the OBBB has triggered several IRS actions to enforce updated compliance obligations:

  • 1099-K Threshold Reverts: The reporting threshold for third-party payment processors returned to $20,000, down from higher levels, affecting platforms and merchants. The IRS issued FAQs in Fact Sheet 2025-08 to clarify new reporting obligations. (irs.gov)
  • ERC (“Employee Retention Credit”) Limitations: For credits or refunds claimed for Q3 and Q4 2021 but filed late (after January 31, 2024), the OBBB limits eligibility or refunds; FAQs issued in Fact Sheet 2025-07. (irs.gov)
  • PTIN Renewal Fee and Rule Change: All tax preparers must renew PTINs annually; IRS has changed fee structure to $10 plus contractor costs under proposed regulation. Maintaining valid PTINs is essential for any person preparing returns for compensation. (irs.gov)

Compliance Action Plan for Businesses and Practitioners

  • Merchants and Marketplaces: Review platform payouts; reconcile with Form 1099-K filings. If aggregates reach $20,000 via third-party platforms, reporting kicks in.

  • Credit Claims (ERC): If planning to claim or assert refund of ERC, check whether the date of filing is before the OBBB cutoff. Review whether documentation satisfies “timeliness” provisions.

  • Tax Preparers & Firms: Renew PTIN as required. Ensure user fees are accounted for in your budgeting. Maintain rigorous records of billing for each return you prepare.

  • Update Internal Controls: Verify all employees or contractors who prepare returns are properly registered. Use checklists to ensure compliance thresholds are met or not exceeded.

Practical Examples

  • Marketplace Seller: If you sell on multiple platforms, scan all income from each. Under the reverted 1099-K threshold, earning $21,000 via a single platform will trigger reporting. Without awareness, potential non-compliance.

  • Small Accounting Firm: Two preparers must renew PTINs. One pays new $10 base fee plus contractor portion; failure to renew invalidates returns you submit.

  • Business Claiming ERC: A company filed a claim for Q4 2021 after the Jan 31, 2024 deadline. Under FAQs, most of that claim may now be disallowed; need to assess exposure.

Compliance Reminders

  • Deadlines matter: Many of these rules have filing cutoffs and pivotal dates. Check dates in your specific case.

  • Record Evidence: Documentation, communications, ledger entries all help in case of IRS audits.

  • Stay Updated: IRS FAQ releases and notices may change guidance—subscribe or follow updates.

Bottom Line

The One, Big, Beautiful Bill has introduced important thresholds and procedural changes. Being proactive—especially for 1099-K obligations, tax preparer compliance, and credit claims—can prevent costly missteps and audits in the coming tax seasons.

Sources

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