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IRS Delays Deadline for Distribution of Forms 1095-C & 1095-B

reportingThe IRS issued Notice 2016-70 which delays the deadlines for employers and health insurers to distribute Forms 1095-C and 1095-B to applicable employees. With the delay, the deadlines are now as follows:

  • March 2, 2017 – employee statements must be distributed (previously January 31st)
  • February 28, 2017 – forms 1094-C & 1094-B must be submitted if submitting hard copies
  • March 31, 2017 – forms 1094-C & 1094-B must be submitted if submitting electronically

As with last year’s reporting, copies of all 1095-Cs and 1095-Bs distributed to employees are included with the IRS submissions.

In addition, the IRS has extended the “good faith” transition relief for 2016 filings similar to 2015 reporting. This good faith relief does not excuse employers from completing the reporting, but it lowers the standard by which the content of the filings will be judged by the IRS.

Even in light of uncertainty about ACA requirements following the election results, it is advised to proceed with compliance with reporting and Play-or-Pay requirements.

Information provided by: Jason Cogdill, Attorney at Law

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