On December 28th, 2015, mere weeks before the first set of deadlines, the IRS released Notice 2016-4, extending the due dates for ACA information reporting.
The extension, aimed at giving both employers and insurers time to comply, affects two major deadlines for reporting under Internal Revenue Code sections 6055 (Insurer Reporting) & 6056 (Large Employer Reporting):
- Due Date for Furnishing Statements to Individuals (1095-B & 1095-C): From February 1, 2016 to March 31, 2016
- Due Date for Filing with the IRS (1094/1095-Bs & 1094/1095-Cs): From February 29, 2016 to May 31, 2016 (if filing on paper); and from March 31, 2016 to June 30, 2016 (if filing electronically)
*Please note: Previous provisions on automatic and permissive reporting extensions will not apply to these extended due dates.
In addition to granting the above extensions, IRS Notice 2016-4 also provides guidance to individuals who might not receive a form 1095-B or 1095-C by the time they file their 2015 tax returns. It is anticipated that most taxpayers will be unaffected by the extension and will, as with last year, simply check a box on their tax return indicating that they had coverage in 2015.
Importantly, the notice states that even though extensions have been provided, the IRS is ready to accept filings beginning in January 2016. Employers and other coverage providers are encouraged to furnish statements and file the information returns as soon as they are ready.
The full IRS Notice 2016-4, including background on the ACA reporting requirements, can be found here. As always, please do not hesitate to reach out with any questions, comments or concerns.