December 30, 2015

The IRS has good news for many employers. IRS Notice 2016-4 extends the due dates for applicable large employers and other reporting entities to file 2015 information reporting required by the Affordable Care Act (ACA). Large employers are still required to file information returns and otherwise comply with the ACA, but the due date for providing Form 1095-B and Form 1095-C to individuals moved from February 1, 2016 to March 31, 2016. The due date for filing Form 1094-B and Form 1095-C with the IRS is further delayed. Large employers who are filing by mail now have untilMay 31, 2016 to file reporting returns, and those who are filing electronically have until June 30, 2016 to submit reporting forms online.

The Notice serves as another form of ACA transitional relief, applying only to reporting for tax year 2015 and the 2016 filing deadlines for Form 1095-B, Health Coverage, Form 1095-C, Employer-Provided Health Insurance Offer and Coverage, Form 1094-B, Transmittal of Health Coverage Information Returns, and Form 1094-C, Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns.

The IRS is prepared to accept information returns beginning in January 2016 and ALEs who do complete the required forms prior to the new deadlines are encouraged to submit them as soon as the forms are ready. The notice reminds large employers of the ACA’s provision for imposing penalties for failing to timely file an information return or for filing an incorrect or incomplete information return. For 2015 coverage, the IRS will not impose penalties related to information reporting (under section 6721 and 6722) due to errors or incomplete information so long as the reporting entities make a timely filing and can show they have made good faith efforts to comply with the information reporting requirements.

Under Notice 2016-4, the provisions regarding automatic and permissive extensions of time for filing information returns will not apply in 2015 because of the now-automatic extension of due dates. The Notice warns that additional requests for extensions will not be formally granted. Large employers who fail to comply with the extended due dates are subject to penalties under section 6722 or 6721 for failure to timely furnish and file information returns.

This is intended to be a brief overview of the recent announcement delaying ACA Reporting for large employers for calendar year 2015 filed and furnished in 2016 and does not address any other application of the ACA. If you have any questions about the application of the ACA, including its reporting requirements, please contact us. 

Ahlers & Cooney’s Labor & Employment and Education Practice Groups

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Beenken, Katherine


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