What exact items are on the IRS Reportable Items List for precious metals and how has it changed over time?
Executive summary
The IRS Reportable Items List for precious metals is not a simple catalog of coin names but a rule set tying reportability to metals (gold, silver, platinum, palladium), specific product forms and brands, and minimum purity and quantity thresholds derived from CFTC‑approved futures contract standards; dealers must file Form 1099‑B when customers sell items that meet those criteria [1] [2] [3]. The list and its practical application have evolved through IRS revenue procedures, industry negotiations (notably with the Industry Council for Tangible Assets in 1992), and periodic clarifications from trade groups and regulators through the 2020s [4] [5] [6].
1. What “reportable items” means in IRS rules and why it exists
Reportable items are precious‑metal products whose sale by a customer to a dealer triggers information reporting on Form 1099‑B; the reporting authority is anchored in whether the metal form and quantity are deliverable under Commodity Futures Trading Commission (CFTC)‑approved regulated futures contracts (RFCs), so the IRS treats only those forms/quantities as reportable, not all metal sales generally [1] [2] [7]. The rule aims to give the IRS visibility into non‑wage income and capital gains from dealer‑facilitated bullion sales [8] [9].
2. The “exact items” the industry and IRS treat as reportable — the practical list
Industry guidance and IRS instructions point to sets of bullion bars and coins that match CFTC quality (fineness/purity) and minimum quantity thresholds; when those two conditions are met the item is treated as reportable, which practically covers certain standardized gold, silver, platinum and palladium bars and branded products specified by the IRS/industry agreements rather than an exhaustive species list in a single public table [2] [4] [1]. Examples repeatedly cited in dealer materials are that many branded bullion bars meeting CME/CFTC contract specs are reportable, while American Gold and Silver Eagle coins, many fractional gold coins, and some other coins and items are commonly treated as exempt regardless of quantity [10] [11] [12]. Some dealers and guides also single out that 100‑oz silver bars and privately‑minted Silver Eagles have been treated as non‑reportable in practice [12].
3. The quantitative and purity thresholds and aggregation rules
Reportability turns on both purity/quality and minimum quantity: even a form approved for RFC trading is not reportable if sold in quantities below the CFTC‑required minimum by weight or number of items, and dealers must aggregate a single customer’s sales over a 24‑hour period to determine reportability unless they know a customer is structuring to avoid reporting [1] [7]. The IRS instructions explicitly state the quantity thresholds matter and that exceptions apply where CFTC approval does not cover the product or where required quantity isn’t met [1] [7].
4. How the list has changed over time and why
The reporting regime traces to IRS rules from the 1980s and was materially clarified after industry negotiations in 1992 when the ICTA reached understanding with the IRS about “reasonable reporting requirements” for certain bullion products; since then industry groups (ICTA/NCBA and others) have periodically sought further clarification and updated “approved brands” guidance, most recently in the 2020s as new products and futures‑market standards evolved [4] [5] [6]. IRS instruction updates (the Form 1099‑B instructions) continue to emphasize the CFTC linkage and quantity tests, reflecting incremental, technical changes more than wholesale rewrites of policy [7] [1].
5. Dealer practice, cash reporting overlap, and real‑world complexity
In practice dealers combine three parallel reporting obligations: 1099‑B for reportable bullion sales per the RFC/quantity rules, Form 8300 for single‑transaction cash receipts exceeding $10,000, and internal compliance choices where some dealers voluntarily report or exempt items differently; as a result customers see variation in what different dealers identify as reportable and why [11] [12] [2].
6. Conflicting interpretations, industry influence and remaining limits of public documentation
Industry trade groups have repeatedly negotiated with the IRS to narrow or clarify reportable items, producing guidance the trade treats as the practical list, which creates a dynamic where dealers’ economic and reputational interests influence which items are emphasized as reportable or exempt; the public federal documentation focuses on rules (CFTC link, quantities) rather than a single, exhaustive named list, so authoritative specifics often live in industry‑IRS clarifications rather than a simple IRS table [4] [6] [1]. Where a precise, up‑to‑date roster of approved brands and itemized thresholds is required, primary IRS instructions and the industry guidance documents cited here must be consulted together; this reporting draws on both legal tests and negotiated industry practice [5] [4].