It’s Déjà Vu All Over Again: IRS Delays Form 1095 Distribution Deadline

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Similar to last year, the IRS has extended the deadline for the distribution of Form 1095 to individuals. More information, direct from the source, can be found in IRS Notice 2016-70.

Deadline to Distribute Form 1095-B and Form 1095-C to Individuals Extended
The original deadline for distributing Form 1095-B and Form 1095-C to individuals was January 31, 2017. The new deadline is March 2, 2017. The extension provides Applicable Large Employers (ALEs), self-insured group health plans, and health insurance carriers more time to populate and distribute the forms. The IRS will not grant additional 30-day extensions.

Filing Deadlines Remain Unchanged
IRS Notice 2016-70 does NOT change the deadlines for filing forms with the IRS. Filers filing fewer than 250 returns may file in paper. The deadline for paper filing is February 28, 2017. Filers filing 250 or more returns must file electronically through the AIR system. The deadline for electronic filing remains March 31, 2017.

Good Faith Compliance Standard Extended to 2016
For 2015, the IRS provided a good faith compliance standard protecting filers from penalties under Code 6721 and 6722.  The IRS initially indicated this good faith compliance standard would no longer be available for 2016. However, Notice 2016-70 extends the good faith standard to the 2016 filing cycle as well. This relief applies to missing and inaccurate information required on the forms, but not to forms that are not filed timely.

Individual Income Tax Filings – No Form 1095 Required
The extension means some taxpayers may not receive a Form 1095 before they are ready to file individual income taxes. Taxpayers may rely on other information provided by their employer or coverage provider to determine eligibility for premium tax credits and to confirm Minimum Essential Coverage was maintained for all months of the 2016 tax year. Taxpayers are not required to wait to receive a Form 1095 before filing individual income tax returns.

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