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January 2016  

IRS ISSUES DELAY IN REQUIREMENTS TO FURNISH FORMS 1094 AND 1095 UNDER ACA.

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IRS Issues Delay in Requirements to Furnish Forms 1094 and 1095 under ACA. 

On December 28, 2015, the IRS announced an extension of the due dates for 2015 Patient Protection and Affordable Care Act (ACA) information reporting by employers, insurers, and other reporting entities. The transition relief provided applies to the furnishing of Forms 1094-C and 1095-C to individuals, as well as filing applicable forms to the IRS, as required under Internal Revenue Code sections 6055 and 6056.

The announcement provides for an automatic 60 day extension for employers to provide Forms 1095-B and 1095-C that must be distributed to employees from January 31st to March 31st each year, except in 2016, it will be February 1st, 2016 instead of Januay 31st since the 31st is a Sunday. The notice also automatically extends the due date for the submission of Forms 1094-B and 1094-C from March 31, 2016 to June 30, 2016 if filing electronically (the extension if not filing electronically is extended from February 28, 2016 to May 31, 2016).

 
The notice also explains that some employees who enrolled in coverage through the Federal or State Marketplace (the Public Exchange) could be affected by the extension if they do not receive their Forms 1095-C before they file their income tax returns. However, the individuals who rely upon other information received from employers about their offers of coverage for purposes of determining eligibility for the premium tax credit when filing their income tax returns need not amend their returns once they receive their Forms 1095-C or any corrected Forms 1095-C from the employer. 

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