Yellow Light (Again): IRS Extends ACA Deadline to Furnish Forms

On November 18, 2016, the IRS extended the due date for employers to furnish 2016 Form 1095-B and Form 1095-C to individuals from January 31, 2017 until March 2, 2017. The IRS stated that the extension is appropriate because a substantial number of employers need additional time to gather and analyze the information necessary to prepare the forms.

Notice 2016-70 does not extend the deadline for filing the 1094-B, 1095-B, 1094-C or 1095-C with the IRS. The deadline to file these forms is February 28, 2017, or March 31, 2017 if filing electronically.

President-Elect Trump will take office on January 20, 2017. In light of the IRS extension and campaign rhetoric, it is becoming increasingly likely that employers will not be required to distribute and/or file the 2016 1094 and 1095 forms at all.  It would be helpful to all employers if the federal government would provide definitive guidance on this issue no later than the end of January.

About Jim Hamilton

I am an employee benefits partner with Bose McKinney & Evans LLP. My broad-based practice covers health and welfare arrangements, insurance, executive compensation and federal and state taxation. Among other areas, I have specific experience with PPACA, HIPAA, COBRA, ERISA and numerous other state and federal laws affecting employee benefit plans.
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