NCBA Advocacy Leads to IRS Update Clarifying Non-Reportable Precious Metals Sales

The National Coin & Bullion Association (NCBA) today announced a key victory in its ongoing efforts to ensure clear and accurate guidance from the Internal Revenue Service for precious metals reporting requirements. Following sustained advocacy by NCBA leaders, the IRS has revised the instructions for Form 1099-B, removing a misleading example that has caused confusion among dealers, brokers, and collectors in the numismatic and bullion communities.

The change, posted on January 30, 2026, addresses the “Sales of precious metals” section on page 5 of the 2025 and 2026 instructions. Draft versions included an example referencing “a single gold coin,” which implied that even small, individual coin sales might trigger Form 1099-B reporting—despite the IRS’s earlier 2024 clarification that such transactions are not reportable when quantities fall below the minimum required for a Commodity Futures Trading Commission (CFTC)-approved regulated futures contract (RFC).

The updated text will now read clearly and concisely:

“A sale of a precious metal (gold, silver, platinum, or palladium) in any form for which the Commodity Futures Trading Commission (CFTC) has not approved trading by regulated futures contract (RFC) is not reportable. Further, even if the sale is of a precious metal in a form for which the CFTC has approved trading by RFC, the sale is not reportable if the quantity, by weight or by number of items, is less than the minimum required quantity to satisfy a CFTC-approved RFC.

“Sales of precious metals for a single customer during a 24-hour period must be aggregated and treated as a single sale to determine if this exception applies. This exception does not apply if the broker knows or has reason to know that a customer, either alone or with a related person, is engaging in sales to avoid information reporting.”

This revision aligns the published instructions with the IRS Office of Chief Counsel’s 2024 guidance, eliminating the potential for misinterpretation that individual or sub-contract–minimum sales (such as individual coins or small quantities of bullion) require broker reporting on Form 1099-B.

The adjustment is the result of persistent engagement by NCBA representatives. In late 2023 and early 2024, NCBA AML advisor Gary Knaus and general counsel Jimmy Hayes collaborated with IRS officials to secure the initial clarification. When the problematic “single gold coin” example persisted in the 2025 instructions and drafts for the 2026 version, executive director David Crenshaw followed up with written requests in late 2025 and early 2026. A key meeting with IRS counsel on January 14, 2026, reinforced the need for the update.

NCBA extends its appreciation to the attorney and team at the IRS Office of Chief Counsel for their responsiveness and for facilitating this important correction. The updated instructions are currently reflected on the IRS product page for Form 1099-B (irs.gov/forms-pubs/about-form-1099-b) under “Recent Developments,” including a dedicated notice of the change, and the new wording will be updated in the officially published instructions in the coming months.

“This is a significant step forward for comprehension in the precious metals and numismatic markets,” said Crenshaw. “By removing the confusing example, the IRS has reduced uncertainty for dealers and investors preparing for the 2026 tax year, ensuring better compliance without unnecessary paperwork for non-reportable transactions.”

Numismatic professionals, bullion dealers, and collectors are encouraged to consult the revised IRS instructions directly at irs.gov for full details on precious metals reporting rules. NCBA remains dedicated to advocating for precise, practical tax guidance that supports the industry.