This notice is relevant to organizations who are considered an Applicable Large Employer (ALE) - employing 50 or more full-time U.S. employees, including full-time equivalents - as defined by the Affordable Care Act (ACA).

On December 28, 2015 the Internal Revenue Service (IRS) issued Notice 2016-4 extending the Form 1094-C and 1095-C due dates for both furnishing to individuals and filing with the IRS. The new IRS due dates are as follows:

Forms 1094-C and 1095-C are information returns designed to report an employer’s offer of health coverage and an employee’s enrollment in employer-sponsored self-insured health coverage. These forms are used by employers to meet the “furnish and file” mandate of the ACA.

Employee Tax Returns

Notice 2016-4 also includes guidance for employees who, as a result of the new March 31 due date to furnish forms, may not receive a 1095-C before they file their 2015 individual tax returns. For the most part, individual taxpayers who enroll in coverage will not be affected by this extension and should file their tax returns as they normally would.

Individuals who enrolled in coverage through the Marketplace, but did not receive a determination that the offer of employer-sponsored coverage was not affordable, could be affected by the extension if they choose to file their income tax return before they receive their Forms 1095-C.  Advise such individuals to consult with their own tax advisors for additional guidance.

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IRS Extends ACA Reporting Due Dates

Dec 31, 2015

This notice is relevant to organizations who are considered an Applicable Large Employer (ALE) - employing 50 or more full-time U.S. employees, including full-time equivalents - as defined by the Affordable Care Act (ACA).

On December 28, 2015 the Internal Revenue Service (IRS) issued Notice 2016-4 extending the Form 1094-C and 1095-C due dates for both furnishing to individuals and filing with the IRS. The new IRS due dates are as follows:

  • March 31, 2016 (formerly February 1) for furnishing Forms 1095-C to employees and covered individuals.
  • May 31, 2016 (formerly February 29) for employers filing paper Forms 1094-C and 1095-C with the IRS
  • June 30, 2016 (Formerly March 31) for employers filing Forms 1094-C and 1095-C electronically with the IRS, including bulk filers such as Ceridian.

Forms 1094-C and 1095-C are information returns designed to report an employer’s offer of health coverage and an employee’s enrollment in employer-sponsored self-insured health coverage. These forms are used by employers to meet the “furnish and file” mandate of the ACA.

Employee Tax Returns

Notice 2016-4 also includes guidance for employees who, as a result of the new March 31 due date to furnish forms, may not receive a 1095-C before they file their 2015 individual tax returns. For the most part, individual taxpayers who enroll in coverage will not be affected by this extension and should file their tax returns as they normally would.

Individuals who enrolled in coverage through the Marketplace, but did not receive a determination that the offer of employer-sponsored coverage was not affordable, could be affected by the extension if they choose to file their income tax return before they receive their Forms 1095-C.  Advise such individuals to consult with their own tax advisors for additional guidance.