Final Forms for ACA Reporting Released

On Sept. 28, 2017, the Internal Revenue Service (IRS) released final 2017 forms for reporting under Internal Revenue Code (Code) Sections 6055 and 6056.

  • 2017 Forms 1094-C and 1095-C (and related instructions) are used by applicable large employers (ALEs) to report under Section 6056, as well as for combined Section 6055 and 6056 reporting by ALEs who sponsor self-insured plans.
  • 2017 Forms 1094-B and 1095-B (and related instructions) are used by entities reporting under Section 6055, including self-insured plan sponsors that are not ALEs.

Final instructions for 2017 were released in early October. The 2017 forms are substantially similar to the 2016 versions, except that sections related to expired Section 4980H Transition Relief were removed.

IMPORTANT DATES

January 31, 2018: Individual statements for 2017 must be furnished by Jan. 31, 2018.

February 28, 2018: IRS returns for 2017 must be filed by Feb. 28, 2018 (April 2, 2018, if filed electronically, since March 31, 2018, is a Saturday).

The IRS does not anticipate extending the filing or furnishing deadlines for 2017 reporting.

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.