For the 2015 tax year, some employers and other entities are required to file information returns containing the type and period of health insurance coverage provided to employees. The IRS recently announced that it's extending the deadlines for filing Forms 1094 and 1095. This article reveals the new deadlines.

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Good News in the New Year IRS
Extends ACA Filing Deadlines

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Employers and other organizations got some good news from the IRS for the
start of the new year. The tax agency announced that it's extending the due
dates for filing 2015 Affordable Care Act (ACA) information returns. This gives
employers extra time to complete two tasks:
1. Provide the forms to the recipients and
2. File the forms with the IRS.

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Background information. Under Internal Revenue Code Section 6055, health
coverage issuers, certain employers, and others that provide "minimum
essential coverage" to individuals are required to file information returns
containing the type and period of coverage. They're also required to furnish
related information statements to covered individuals, beginning with
calendar year 2015. If your entity is subject to these reporting requirements,
you must file IRS Forms 1094-B, "Transmittal of Health Coverage Information
Returns," and 1095-B, "Health Coverage.“
Code Section 6056 requires applicable large employers (ALEs) to report to the
IRS information about the health care coverage, if any, they offered to full-
time employees (for example, an individual who is employed on average for at
least 30 hours of service per week). This information is needed in order to
administer the employer shared responsibility provisions of the ACA and to
assist in determining eligibility for the premium tax credit. ALEs are generally
defined as employers with at least 50 full-time employees (including full-time
equivalent employees) in the previous year.

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ALEs are required to file Form 1094-C, "Transmittal of Employer Provided
Health Insurance Offer and Coverage Information Returns," and Form 1095-C,
"Employer Provided Health Insurance Offer and Coverage," with information
about the health care coverage, if any, they offered to full-time employees.

5. What's the Difference Between the Forms?
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1. Forms 1094-B and 1095-B are filed by providers of health coverage,
including insurers, some self-insuring employers and others.
2. Forms 1094-C and 1095-C are filed by applicable large employers.

6. How Much Extra Time Do You Get?
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The original deadlines for filing 2015 ACA information returns were the same
as for filing W-2 and 1099 forms. In other words, they were required be filed
with the IRS no later than February 29, 2016 (March 31, 2016, if filed
electronically). Employers could apply for a 30-day extension of the deadline
by filing an IRS form.
In addition, employers were originally required to provide 2015 ACA
statements to employees no later than February 1, 2016 (because January 31,
2016 is a Sunday).

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If you're not filing electronically, the IRS has now extended the due date:
• To March 31, 2016 for furnishing to individuals 2015 Forms 1095-B and
1095-C (from February 1, 2016).
• To May 31, 2016 for filing with the IRS 2015 Forms 1094-B, 1095-B, 1094-
C, and Form 1095-C (from February 29, 2016). If you're filing
electronically, the deadline is now June 30, 2016 (from March 31, 2016).
The IRS is prepared to accept the information returns on Forms 1094-B, 1095-
B, 1094-C, and 1095-C beginning in January 2016. However, following
consultation with stakeholders, the U.S. Department of the Treasury and the
IRS determined that some employers, insurers, and other providers of
minimum essential coverage need additional time to adapt and implement
systems and procedures to gather and report the required information.

8. Will You Be Able to Get Further Extensions after these Deadlines?
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In view of the extensions announced recently by the IRS, the provisions
regarding automatic and permissive extensions of time for filing information
returns and permissive extensions of time for furnishing statements won't
apply to the extended due dates. In other words, there will be no further
extensions.

9. Are There Penalties for Not Filing?
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Employers or other coverage providers that don't comply with the new
deadlines will be subject to penalties for failure to timely furnish and file.
However, employers and other coverage providers that don't meet the
extended due dates are still encouraged to furnish and file, and the IRS will
take such furnishing and filing into consideration when determining whether
to abate the penalties for reasonable cause.
In addition, the IRS will take into account whether an employer or other
coverage provider made reasonable efforts to prepare for reporting the
required information to the IRS and furnishing it to employees and covered
individuals. These efforts include gathering and transmitting the necessary
data to an agent to prepare the data for submission to the IRS, or testing an
employer's ability to transmit information to the IRS. The tax agency will also
consider the extent to which the employer or other coverage provider is
taking steps to ensure that it's able to comply with the reporting requirements
for 2016.

10. What about Individual Taxpayers?
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The new IRS notice also provides guidance to individuals who might not
receive Form 1095-B or Form 1095-C by the time they file their 2015 personal
income tax returns (because their employers took advantage of the extension
opportunity).
In these cases, according to the IRS Notice, "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." Individuals don't need to send
this information to the IRS when filing their returns but should keep it with
their tax records.

11. Need Help?
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Contact your tax adviser if you need more information or assistance to comply
with the Form 1094/1095 filing requirements.

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