The Protecting Americans from Tax Hikes (PATH) Act of 2015 requires Forms 1099-MISC reporting non-employee compensation (NEC) in box 7 to be filed by January 31 for both paper filing and electronic filing.
If any of your Forms 1099-MISC reporting NEC will be filed after the January 31, 2018 due date, the IRS recommends you separate the submission of those Forms 1099-MISC from the submission of any Forms 1099-MISC that do not report NEC.
The IRS may inadvertently treat all Forms 1099-MISC in a combined submission as subject to the Section 6721 penalty for failure to file by January 31, even though many of the forms might not be due until February 28 or March 31.
Additional guidance on how to file 2017 Forms 1099 MISC:
- Publication 1220, Specifications for Electronic Filing of Forms 1097, 1098, 1099, 3921, 3922, 5498, and W-2G Tax Year 2017 (page 16)
- Filing Forms 1099-MISC With NEC in Box 7 with the IRS