Notice 2026-4

The Committee of Annuity Insurers, a coalition of life insurance companies, supports revising the rules to facilitate the electronic furnishing of payee statements. They specifically request that the IRS allow for broader electronic consent, permit default electronic delivery, and remove outdated requirements regarding hardware/software specifications and recipient access demonstrations.

Obelisk Tech Systems Inc. opposes the proposed action, arguing that it contains twelve procedural and substantive defects regarding statutory compliance, regulatory review, and small business impact. The company requests that the IRS and Treasury withhold final guidance until these legal and procedural issues are corrected.

The American Bankers Association supports the Treasury and IRS's efforts to modernize and expand electronic furnishing rules for payee statements. They recommend adopting a flexible, principles-based framework that includes an opt-out model for electronic delivery, consistent rules across all statement types, and flexible procedures for handling electronic delivery failures.

Fidelity Investments supports the IRS and Treasury's efforts to modernize rules for the electronic furnishing of payee statements, noting that electronic delivery aligns with modern customer behavior. The company advocates for making electronic delivery the default, simplifying consent procedures, enhancing 1099-B composite forms, and applying these rules consistently across both traditional and digital asset brokers.

Ledgible, a tax reporting policy organization, supports modernizing regulations to allow for the electronic furnishing of payee statements for "digital-native" accounts. They argue for an account-based framework to exempt digital-native accounts from paper mailing requirements and recommend including Form 1099-MISC on 1099-B composite statements for various types of account-related income.

The commenter expresses a series of legalistic demands and requests regarding tax regulations, identity theft, and the use of emergency economic powers. The comment does not take a clear position for or against the specific regulatory modification described in Notice 2026-4.

The commenter, a professional technologist, opposes making electronic tax statements the default because it shifts the technological burden and costs from large brokerages to individual customers who may lack the necessary hardware, skills, or reliable internet. They argue that paper statements are more reliable for traditional tax preparation, reduce the risk of data breaches, and should remain the default to avoid discriminating against elderly or less tech-savvy individuals.