The U.S. Treasury Department and the Internal Revenue Service extended the deadlines on both ACA tax form filings for Forms 1094-B and 1094-C and 1095-B, and 1095-C as well as the Cadillac Tax. The extension was granted in order to help employers, health care insurers, and payroll service providers additional time to work through the data and comply with reporting requirements.
The U.S. Treasury Department and the Internal Revenue Service extended the deadlines on both ACA tax form filings for Forms 1094-B and 1094-C and 1095-B, and 1095-C as well as the Cadillac Tax. The extension was granted in order to help employers, health care insurers, and payroll service providers additional time to work through the data and comply with reporting requirements. For complete details from the IRS, please see the IRS website.
The Cadillac Tax is an excise tax on ‘high cost’ employer-sponsored health coverage. The tax imposes a 40 percent excise tax on employee’s benefits exceeding the federal maximum dollar value. The Cadillac tax was delayed two additional years from plan years beginning on or after January 1, 2018 to January 1, 2020. The dollar limit would have been to be at least $100,200 for single coverage and $27,500 for family coverage.
Affordable Care Act (ACA) reporting includes reporting requirements for both employers and individuals to demonstrate health coverage throughout the reporting year. IRS Notice 2016-4 extended the deadlines for the 2015 ACA Employer-Provided Health Insurance Offer and Coverage reporting. The delays are:
Forms 1095-B and 1095-C – Deadline to deliver forms to individuals
· Original due date was February 1, 2016
· Extended due date is now March 31, 2016
Forms 1094-B and 1094-C – Deadline to file forms with the IRS (paper filing)
· Original due date was February 29, 2016
· Extended due date is now May 31, 2016
Forms 1094—B and 1094-C – deadline to file forms with the IRS (Electronic filing – required for employers filing more than 250 forms)
· Original due date was March 31, 2016
· Extended due date is now June 30, 2016
Due to this extension, the extensions previously offered by the IRS will no longer be available. The IRS will not process or formally grant any additional requests for delay of filing the 2015 forms. The IRS does advise that if businesses cannot meet the extended deadlines that they should still distribute and provide the IRS with forms as soon as possible in order to mitigate any and reduce penalties that may apply.
Individuals do not need to submit Form 1095-C along with their 2015 tax returns and do not even need to wait for receipt of the form in order to complete their 2015 taxes. Other information received from employers or insurance providers about their offers of coverage can be used to determine eligibility for the premium tax credit and/or filing tax returns. If the employer sends an amended Form 1095-C, individuals do not need to amend their returns or send copies to the IRS.
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Please be advised that, based on current IRS rules and standards, any advice contained herein is not intended to be used, nor can it be used, for the avoidance of any tax penalty that the IRS may assess related to this matter. Any information contained in this article, whether viewed or subsequently printed, cannot be relied upon as qualified tax and accounting advice. Any information contained in this article does not fall under the guidelines of IRS Circular 230