What reporting requirements exist for private precious metal transactions in Washington?
Executive summary
Washington state recently rewrote how dealers and sellers of precious metals are treated for state taxes: effective Jan. 1, 2026, sales of “precious metal bullion” and “monetized bullion” are taxable as tangible personal property for retail sales tax and retail B&O tax [1]. At the federal level, dealers face longstanding reporting rules: cash payments over $10,000 trigger Form 8300 and dealers in precious metals are subject to Treasury/FinCEN reporting rules and cross-referenced IRS dealer reporting (31 C.F.R. parts 1010/1027) [2] [3].
1. Washington changed the tax landscape — dealers must collect sales tax and B&O on bullion
State guidance from the Washington Department of Revenue explains that the legislature’s 2025 bills reclassify sales of processed precious metal bullion and monetized bullion so that, beginning Jan. 1, 2026, gross income from those sales is taxable under the Retailing classification and sellers must collect retail sales tax and pay retail B&O tax [1] [4]. The DOR defines “precious metal bullion” as refined or smelted metal valued by content and “monetized bullion” as coins or money used as an exchange medium under law, with some exclusions for material sold for manufacture into jewelry [4] [5].
2. The rule change is recent and contentious within the industry
Trade outlets and dealers uniformly flagged the repeal of the prior exemption as a major shift. Industry commentary notes the repeal originated in 2025 legislation and that opponents — including coin and bullion associations — warned the change would harm collectors and dealers; media and industry analyses mark October 2025 and January 2026 as key dates in implementation and repeal timelines [6] [7]. The Department of Revenue’s guidance and subsequent industry write-ups signal a significant compliance and pricing impact for Washington sellers and buyers [1] [7].
3. Federal reporting lines that apply to precious-metal dealers (cash reporting and 1099-B nuances)
Federal rules require dealers to file Form 8300 for receipt of cash in excess of $10,000 in a single transaction or related transactions within 24 hours — a longstanding anti‑money‑laundering measure commonly cited by dealers’ resource pages [8] [9]. Separate Treasury/FinCEN regulations specific to dealers in precious metals, stones or jewels (31 C.F.R. Part 1027) point dealers to subpart C of 31 C.F.R. Part 1010 for currency-reporting requirements and make dealers subject to reporting obligations in that subpart [3] [2].
4. Sales reporting (1099-B) is limited and conditional — industry guidance vs. IRS instruction
Dealer and industry guides emphasize that most purchases and sales of physical bullion are not routinely reported on Form 1099-B to the IRS; reporting on 1099-B applies in narrow circumstances tied to the Commodity Futures Trading Commission’s (CFTC) regulated futures contract (RFC) list and minimum-quantity rules noted in IRS instructions [10] [11]. Industry FAQs and resource guides say Form 1099-B reporting for precious metals sales is “extremely rare” unless the sold items and quantities meet RFC definitions [10] [9].
5. Practical compliance takeaways for buyers and private sellers in Washington
Buyers and sellers in Washington should now expect sales tax to be added to purchases of bullion and monetized coins after Jan. 1, 2026, and dealers should prepare to remit retail B&O tax on those sales per DOR publications [1] [4]. Independently, any cash transaction over $10,000 to a dealer remains reportable under federal law (Form 8300) and dealers must follow the Treasury/FinCEN dealer rules [2] [8]. The sources do not mention additional Washington-specific reporting forms for private individual-to-individual transactions beyond the tax and federal cash-reporting rules; available sources do not mention state-level reporting of private purchases or sales beyond tax collection and the federal cash-reporting requirement [1] [2].
6. Where perspectives diverge and what’s left uncertain
State DOR guidance is explicit on taxation but silent on how enforcement will be prioritized at small private sales versus commercial dealers [1]. Industry outlets and dealer FAQs stress privacy and say routine purchases are not reported — but they also underscore the $10,000 cash threshold and narrow 1099-B triggers, illustrating a tension: dealers promise discretion for ordinary customers while acknowledging specific federal reporting obligations [9] [10] [8]. The supplied sources do not provide Washington administrative guidance about enforcement practice or thresholds for distinguishing casual sellers from dealers; available sources do not mention Washington agency rules on that distinction [1].
If you want next steps, I can pull together the exact statutory citations (ESSB 5794 / Chapter 423, Laws of 2025 and the cited WAC/RCW sections the DOR references) from the DOR notices and the exact federal regulatory text (31 C.F.R. §§ 1010.330 and Part 1027) so you can review the statutes and regs line-by-line [4] [3] [2].