EANE Logo Banner
  
E-Alert!!!
  
ACA 1094 and 1095 Reporting Deadlines Extended!
  
The Internal Revenue Service (IRS) has given employers (and insurance carriers) a belated Christmas present as it has extended the deadlines for Form 1094 and 1095 reporting.

In its Notice 2016-4 - which can be viewed and downloaded here - the IRS has extended the deadlines as follows:

Information:
Original Deadline:
New Deadline:
Furnishing 1095-C's to Employees
February 1, 2016
March 31, 2016
Furnishing 1094-C and 1095-C to IRS (Paper)
February 29, 2016
May 31, 2016
Furnishing 1094-C and 1095-C to IRS (Electronic)*
March 31, 2016 
June 30, 2016

  • *Note:  Employers generating 250 or more forms must utilize the electronic method when furnishing to the IRS.

For self-insured employers and insurance carriers who may be subject to filing the "B" version of the 1094 and 1095 forms (notably the Form 1094-B and 1095-B), those deadlines have likewise been similarly extended as well with March 31, 2016 being the new deadline for furnishing such forms to plan participants, and May 31st and June 30th being the respective dates for furnishing transmittals to the IRS (for Paper and Electronic transmittals respectively).

Notice 2016-4 also points out that employers and carriers can still follow the original deadlines if they so choose and the IRS will be ready to receive such information for those who remain committed to adhering to the original deadline schedule.

While the impact of these delays may mean that employees or plan participants may not receive their 1095 forms prior to filing their individual tax returns, the IRS has pointed out via this Notice that it is not necessary to furnish 1095 forms when filing income tax returns.  Consequently, the IRS has not made any adjustments to the April 15th deadline for filing income tax returns. 
  



   
  
People.  Business.  Success.
  
Agawam, MA   |  Waterbury, CT   |   Auburn, MA   |  Lincoln, RI