The entity responsible for reporting payment card transactions when a payment settlement entity contracts with a third party, such as an electronic payment facilitator, to settle reportable transactions is the third party entity that submits the instructions to transfer funds to the participating payee's account. This is because the third party entity is the one actually executing the transfer of funds in settlement of the transactions.
Sources:
§ 6050W. Returns relating to payments made in settlement of payment card and third party network transactions
§ 1.6050W-1. Information reporting for payments made in settlement of payment card and third party network transactions.
Publication 1220 (9/2023)
PLR 201836008
PLR 201907006
PLR 201719009
