Are there federal reporting thresholds or 1099 requirements for selling gold or silver privately?
Executive summary
Federal 1099-B reporting for private sales of gold and silver depends on the metal form and quantity: certain listed bullion and coins become reportable only when sold in specified minimum quantities (for example, 1 kilo gold bars or 1,000 troy oz silver bars in many industry summaries), while many common retail coins (e.g., American Gold Eagles) are widely treated as not reportable to dealers under IRS guidance [1] [2] [3].
1. What the IRS instructions actually say — reportability tied to CFTC-approved delivery forms
The IRS instructions for Form 1099‑B state plainly that a sale of a precious metal in a form that the Commodity Futures Trading Commission (CFTC) has not approved for delivery under a regulated futures contract is not reportable; even for CFTC‑approved forms, sales are reportable only when the quantity meets the CFTC‑approved minimums by weight or number of items [1]. That means reportability is a technical match between the item’s form and the contract’s delivery specs, not a blanket “all gold and silver sales” rule [1].
2. How industry thresholds look in practice — kilo bars, 1,000 oz silver, and coin counts
Dealers and trade groups produce checklists that translate the IRS/CFTC interplay into actionable thresholds: many dealer guides show reportable thresholds such as 1 kilogram (32.15 troy oz) or more for each .995+ gold bar, and 1,000 troy ounces for .999+ silver bars; for certain 1‑oz gold coins (Maple Leaf, Krugerrand, Mexican Onza) reportability commonly begins at 25 or more coins in 24 hours [2] [4] [5]. Industry explanations vary slightly on cutoffs and specifications, but they consistently link reporting to specific purity, serial/brand marking, and quantity rules [2] [4].
3. Which common retail coins are widely treated as non‑reportable
Multiple industry commentators and dealer guides say American Gold Eagles and many fractional gold coins are not subject to 1099‑B dealer reporting regardless of quantity because they are not deliverable forms for the relevant CFTC contracts; likewise many silver bullion coins and 90% U.S. coins are excluded from the “reportable items” lists used by dealers [6] [2] [4]. Dealers emphasize that non‑reportability to the IRS via 1099‑B does not eliminate your obligation to report capital gains on your tax return [7].
4. Dealers’ policies and aggregation rules — sales in a 24‑hour window and related accounts
Practical dealer policies require aggregation: sales to the same dealer (or related customers if the dealer suspects relatedness) within prescribed time windows can be aggregated and treated as a single transaction for 1099‑B purposes; several dealer and consumer guides stress that multiple small sales in a day can trigger reporting if they combine to reach thresholds [4] [8]. Failure by a dealer to file required information returns can lead to penalties for the dealer [9] [8].
5. Where interpretation and industry guidance diverge — expect disagreement and updates
Industry sources show disagreement about the precise list of reportable items and the impact of recent rule changes; some dealers reported in early 2025 that silver reporting thresholds had effectively been lifted for many coins, while others continue to treat certain silver items as reportable only in very large, specifically specified bars [10] [4]. The IRS instructions themselves require matching forms to CFTC contract specs, leaving dealers to interpret which commercial products satisfy those specs — a source of ongoing divergence [1].
6. What this means for private sellers — tax filing vs. 1099 reporting
Selling privately or to a dealer: your capital‑gains tax obligations remain independent of whether a dealer files a 1099‑B. Industry and IRS materials repeatedly note that even if no 1099‑B is issued, gains on precious metals remain taxable and should be reported on your tax return [7] [3]. Available sources do not mention a federal rule that private person‑to‑person private sales are reported via a different automatic threshold beyond the 1099-B/CFTC framework; nor do they state that absence of a 1099 relieves reporting obligations on Schedule D [1] [3].
7. Practical advice and the limits of current reporting
If you plan to sell, confirm with the buyer (dealer) what items on their “reportable items” list will trigger a 1099‑B and understand their aggregation rules; consult a tax professional to determine your capital‑gains reporting obligation because dealer reporting and taxpayer reporting are separate responsibilities [7] [9]. Note that dealer checklists and industry interpretations change and differ across sources — the IRS Form 1099‑B instructions remain the controlling text for reportability tied to CFTC‑approved delivery forms [1].
Limitations: this analysis uses only the provided industry and IRS instruction excerpts; it does not substitute for advice from the IRS or a tax professional and does not assert changes outside these sources [1] [2] [4].