business e-file requirements, # of returns

6011(e)(5) says that after 2021, if the business files more than 10 returns, it must e-file. I seem to recall that each form counts on its own, so that if you file 1 federal return, 2 K-1s, 5 1099s, and 8 payroll returns, you're at 16.

I cannot find something that explains this with certainty. I have an older client with several small businesses who is going to be very resistant, and I want to give him a heads up that this year is the last year to paper-file, but I need to be sure.

Thank you.

Treas Reg 301.6011-2 has some info. The examples show the threshold being separate for each type of form. The subsequent regs (-3 and -5) have info for partnerships and corporations.

Correction: the "no aggregation" rule is only under the low-filer exception so I guess they are aggregated otherwise, but some of the examples show more than 250 total returns being allowed to fall under this so....

Shame on me. I didn't scroll down in tax notes, so I didn't see that the regs went beyond 1.6011

Thanks