Eh, I answered my own question in the edit.  

It's not a 1099-MISC because 1099-MISC is for when you pay someone, and sitting in the IRS office, when they use the word "pay", I think they mean USD.  They use the word "cash" repeatedly, and they do not mention commodities or FMV or anything like that.  I'm pretty sure 1099-B is the right form.


It occurred to me that using an exchange may get you out of the 1099-B requirement.  Since the threshold for having to issue a 1099-B is the number of barters (trades) and when you use an exchange your trades are greatly reduced, you may get in under the 100.  For example:

- You trade BTC to the exchange.  (1 trade by you)
- The exchange divides it up.  (XX trades by the exchange)

or

- You offer 1000 shares for sale on the exchange.  (XX trades by the exchange.)
- You withdraw the funds.  (1 trade by you.)

So as long as your Issues + Dividends add up to less than 100 barters per year, you may be in the clear.  (Any lawyers around to interpret this?)

And since there are no operating BTC stock exchanges in the US, I don't think any of the exchanges are subject to the barter exchange reporting requirements.

Thus, it's on the individuals in the US to report their barter income.

Thoughts?