What reporting or recordkeeping requirements would dealers have under Washington gold taxation rules?

1. Why this tax rewrite forces dealers to get their books in order — the headline change that matters

Washington’s repeal of the precious-metals exemption turns previously nontaxable bullion sales into taxable transactions subject to retail sales tax and business & occupation (B&O) tax beginning January 1, 2026. Dealers who sell to end consumers must collect retail sales tax and report under the Retailing B&O classification, while sales to resellers that present a valid reseller permit shift taxation to the Wholesaling classification and remove retail sales tax. This change removes the longstanding carve-out for refined bullion sold solely for its content and thus requires dealers to segregate sales by buyer type and tax treatment to report gross income correctly ^{[1] [3]}.

2. The recordkeeping reality: what dealers will need to retain to justify tax positions

Although Washington guidance does not list an exhaustive new checklist in the materials provided, the effective rules make it unavoidable that dealers must maintain sales records, reseller permits, invoices, evidence of product form, and documentation supporting exempt manufacturing sales to substantiate when transactions qualify for non-retail treatment. Prior practice already required written buyer statements when bullion was sold to be manufactured into jewelry or art to claim exemption; the repeal intensifies the need for contemporaneous documentation because the tax status now pivots on buyer intent and transaction classification ^{[4] [2] [3]}.

3. Federal cash- and transaction-reporting overlays that complicate dealer compliance

Beyond state taxation, federal reporting requirements intersect with bullion trade: dealers who receive over $10,000 in cash or cash equivalents must file IRS Form 8300 and are subject to Suspicious Activity Report considerations, though some court challenges and industry exemptions have narrowed SAR application to certain dealers. These federal duties do not replace state tax filings but add an extra layer of recordkeeping—name, taxpayer identification, transaction details—and legal risk for noncompliance. Dealers should be aware that cash-reporting rules target large cash inflows rather than bullion per se, but in practice bullion trades often trigger federal reporting thresholds ^[5].

4. How commissions and value-added manufacturing still change tax classifications

Washington’s historic treatment taxed commissions from bullion sales under the service and other activities B&O classification and taxed bullion made into manufactured articles (like jewelry) as taxable sales. The repeal preserves those principles in practice by confirming that manufactured forms that add value beyond metal content remain taxable, and that commissions remain a separate taxable activity. Dealers must therefore maintain commission records and records linking raw-metal sales to subsequent manufacturing to support any claims of non-taxable raw-metal disposition or separate service income ^{[4] [2]}.

5. Practical gaps and ambiguities dealers should plan for now

The publicly available summaries and administrative excerpts indicate clear taxability shifts but leave open operational details dealers must resolve: how granularly the Department of Revenue will expect them to track inventory-origin, the acceptable format for reseller permits and buyer statements, and audit timelines. Media accounts flag industry concern about competitiveness and compliance complexity, but concrete administrative rules and guidance documents that specify retention periods, electronic record standards, and audit proof requirements should be consulted as they are issued. Dealers should assume documentation will be scrutinized and prepare recordkeeping systems accordingly ^{[6] [1]}.

6. Timeline, next steps, and where to find authoritative clarification

The operative date for the taxation change is January 1, 2026, creating a finite window for dealers to revise point-of-sale systems, staff training, and bookkeeping to capture taxability flags for each sale. The legislative vehicle referenced is Engrossed Senate Substitute Bill 5794; for compliance clarity, dealers must review the bill text and forthcoming Washington Department of Revenue guidance and bulletin pronouncements, which will define reporting forms, thresholds, and retention expectations. In parallel, dealers should reconcile federal reporting obligations like Form 8300 with state filings because overlapping obligations drive the recordkeeping standard auditors will use ^{[1] [5] [3]}.