Which specific coins and bullion products are on the IRS/CFTC reportable items list and what are their thresholds?
Executive summary
The IRS’s “reportable items” regime for bullion ties not to broad classes like “all gold coins” but to specific forms and quantities that the Commodity Futures Trading Commission (CFTC) has approved for delivery under regulated futures contracts; dealers must file Form 1099‑B when a sale meets those form-and-quantity thresholds (IRS instructions) [1]. The published guidance and industry analyses identify a small, specific list of reportable items (certain sovereign 1‑oz gold coins and pre‑1965 U.S. 90% silver coins) and a handful of bar-size/fineness thresholds (notably 1 kilogram at .995 fineness for some gold bars), but significant ambiguity and recent clarifications from industry groups mean the boundaries are evolving [2] [1] [3].
1. Which coins appear on the historic CFTC/IRS “reportable” list — the short list of sovereign coins
The coins most consistently cited across CFTC/industry references are South African Krugerrands, Canadian Maple Leafs, Mexican 50‑peso (Onza) gold coins, and U.S. pre‑1965 90% silver dimes/half dollars/dollars (the list of coin types the CFTC has historically identified as deliverable forms) [2]. Multiple dealer and trade analyses repeat that modern U.S. bullion products such as American Eagles are NOT on that list and therefore generally are treated as non‑reportable on that basis [2] [4].
2. The numerical thresholds that trigger a 1099‑B for coin sales
For gold coins that match a CFTC‑approved coin form, the IRS instructions and industry reporting commonly use “25 coins” as the illustrative minimum quantity that makes a sale reportable — i.e., a broker selling fewer than the contract’s minimum number (for example a single coin) need not file Form 1099‑B, whereas sales that meet or exceed the contract’s delivery quantity require reporting (IRS instructions; trade reporting) [1] [5]. For U.S. 90% silver coins, the frequently cited threshold is face value: sales of 90% silver U.S. coins exceeding $1,000 face value are treated as reportable by many dealers and trade writeups [6] [7] [8].
3. Bullion bar/round form and fineness thresholds that matter
Industry summaries and CFTC contract specifications show that bar form and minimum fineness/weight determine reportability more than “bullion” as a catch‑all; for “bulk gold” the CFTC‑related minimum commonly cited is 1 kilogram (32.15 troy ounces) at .995 fineness or better — meaning kilo bars (or combinations reaching a kilo) that meet the fineness requirement are treated as reportable under the relevant contracts [2] [9]. Some exchange contract specifications also reference larger commercial sizes (e.g., 100 troy oz. deliverable bars in certain contracts and even 5,000 troy oz. aggregated contract sizes in others), with brand, serial number and production markings required under evolving specs for deliverable bars [10].
4. Key practical limits, dealer guidance, and recent clarifications
The operative IRS rule is not a fixed list but a functional test: a sale is reportable only if the form of metal sold is deliverable under a CFTC‑approved regulated futures contract AND the quantity meets the contract’s minimum delivery quantity; if either element fails, the sale is not reportable per the Form 1099‑B instructions [1]. Industry groups have pushed for and obtained clarifications: the National Coin & Bullion Association reports IRS Office of Chief Counsel guidance that precious‑metal coins and $1,000 face‑value bags of 90% silver do not currently satisfy deliverable contract requirements and therefore are not within the scope of reportable items under current CFTC contracts — a development that alters long‑standing dealer practice in some cases [3] [11].
5. Why ambiguity persists and how dealers act
Because the CFTC’s approved delivery specifications differ by contract and have been updated over time (weights, fineness, brand and marking requirements), dealers and trade publications continue to publish practical “rules of thumb” (25 coins for certain gold sovereigns, $1,000 face value for 90% silver, 1 kg at .995 for kilo bars) but caution that the legal test is technical and can change with CFTC contract approvals or IRS interpretation; several dealer guides explicitly warn readers to confirm active CFTC contract specs and treat industry lists as guidance rather than definitive legal statements [10] [12] [13].
Conclusion
The concrete, repeatedly cited thresholds for reportability are: certain sovereign 1‑oz gold coins (Krugerrand, Maple Leaf, Mexican 50‑peso) reported when sold in quantities that meet contract delivery (commonly cited as 25 coins) and U.S. 90% silver coins reported when sales exceed $1,000 face value; for bars the key trigger widely cited is 1 kilogram at .995 fineness or better for some gold contracts, with exchange‑level contracts sometimes specifying 100‑oz or larger commercial bars and strict brand/fineness marking requirements — but recent NCBA/IRS clarification suggests coins and $1,000 face‑value 90% silver bags may not currently satisfy CFTC deliverable specs, illustrating how the list and thresholds are contingent on current CFTC contract approvals and IRS interpretation [2] [1] [6] [3] [10].