ACA 6055/6056 Reporting Deadlines Delayed

On Dec. 28, 2015, the Internal Revenue Service (IRS) issued Notice 2016‐4 to delay the due dates for filing and furnishing forms under Section 6055 and 6056.

  • The due date for furnishing forms to individuals has been extended from Feb. 1, 2016, to March 31, 2016. 
  • The due date for filing forms with the IRS has been extended from Feb. 29, 2016, to May 31, 2016 (or, from March 31, 2016, to June 30, 2016, if filing electronically).

IMPORTANT DATES

March 31, 2016
Deadline for furnishing Forms 1095‐B and 1095‐C to individuals

May 31, 2016
Deadline for filing Forms 1094‐B, 1095‐B, 1094‐C and 1095‐C with the IRS

June 30, 2016
Deadline for electronically filing Forms 1094‐B, 1095‐B, 1094‐C and 1095‐C

The IRS is encouraging employers and other coverage providers to furnish statements and file information returns as soon as they are ready.

The new deadlines are more generous than prior extensions and apply automatically to all reporting entities. No request or additional documentation is required. Entities that had previously requested extensions will not be receiving formal approval of those requests.

Extended Due Dates are Automatic

Filers are not required to submit any request or other documentation to the IRS to take advantage of the extended due dates provided by Notice 2016‐4.

Because these extensions apply automatically to all filers and are more generous than extensions for 2015 returns and statements that have already been requested by some filers, those requests will not be formally granted.

The previous provisions regarding extensions of time for filing information returns and furnishing statements will not apply to the extended due dates.

These extensions for the Sections 6055 and 6056 information reporting provisions for calendar year 2015 have no effect on the information reporting provisions for other years or on the effective date or application of other ACA provisions.

Impact on Individuals

Some individuals may be affected by the due date extension for employers to furnish information under Section 6056 on Form 1095‐C. The information reported on Form 1095‐C will help employees in determining eligibility for premium tax credits for Exchange coverage. Some individuals who enrolled in Exchange coverage could be affected by the extension if they do not receive their Forms 1095‐C before they file their income tax returns.

As a result, for 2015 only, 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. Individuals need not send this information to the IRS when filing their returns, but should keep it with their tax records.

Similarly, some individual taxpayers may be affected by the extension of the due date for providers of minimum essential coverage to furnish information under Section 6055 on either Form 1095‐B or Form 1095‐C. Individuals generally use this information to confirm that they had minimum essential coverage for purposes of the individual shared responsibility requirements (also known as the individual mandate). As a result of the extension, individuals may not have received this information before they file their income tax returns.

For 2015 only, individuals who rely upon other information received from their coverage providers about their coverage for purposes of filing their returns need not amend their returns once they receive the Form 1095‐B or Form 1095‐C. Individuals should keep this information with their tax records as well.

DISCLOSURE

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The information provided is for informational purposes only and does not constitute legal advice. The information above contains only a summary of the applicable legal provisions and does not purport to cover every aspect of any particular law, regulation or requirement. Depending on the specific facts of any situation, there may be additional or different requirements. This is to be used only as a guide and not as a definitive description of your compliance obligations.