Welcome Relief for Employers
By Jeffrey R. Spencer, CPA, Principal, Ciuni & Panichi, Inc.
The Internal Revenue Service (“IRS”) has issued Notice 2016-4 which automatically extends the due dates of the new Affordable Care Act (“ACA”) reporting forms for the 2015 calendar year. The extension applies to IRS Forms 1094/1095-B (Issuer of Minimum Essential Coverage) and to IRS Forms 1094/1095-C (Applicable Large Employer).
In their Notice, the IRS acknowledged that some Applicable Large Employers (generally employers with 50 or more full-time employees) and some coverage providers need additional time to implement systems to properly capture and report the necessary information to individuals and the IRS.
Therefore, the extended deadline for furnishing the 2015 Form 1095-B and 1095-C to individuals is March 31, 2016 (previously February 1, 2016).
The extended deadline for filing Forms 1094/1095-B and Forms 1094/1095-C with the IRS is June 30, 2016 if filed electronically (previously March 31, 2016). However, if filing less than 250 forms and filing on paper, then the extended deadline is May 31, 2016 (previously February 29, 2016).
Since these forms have potential tax implications for individuals, the IRS is encouraging employers and coverage providers to furnish the statements and file these information returns as soon as they are completed. If you are using a third-party vendor to assist with these ACA filings, then you should discuss the extended filing deadlines with the vendor and determine whether the forms will be filed using the original or the extended due dates.
It is very important for employers to determine whether or not these filings apply to them, and if they do apply, that they make a good faith effort to comply with them. The IRS can assess substantial penalties for noncompliance with these new reporting requirements.
Please contact Jeff Spencer at 216-831-7171 or jspencer@cp-advisors.com for more information on this topic.
Jeff Spencer is a Tax Principal at Ciuni & Panichi, Inc., and he is the head of the employee benefits tax services group.
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