The Internal Revenue Service (IRS) extended the due dates for furnishing Forms 1095-C to individuals from January 31, 2017, to March 2, 2017. These information reports are required under the Patient Protection and Affordable Care Act for large employers (generally those with 50 or more full-time and full-time equivalent employees during the prior calendar year).
The deadline for filing the 2016 Form 1094-C and 2016 Form 1095-C with the IRS was not extended and remains February 28, 2017 (if not filing electronically) and March 31, 2017 (if filing electronically).
The notice also extended transition relief from penalties for incorrect or incomplete information reported on the return or statement if the employer can show it made good-faith efforts to comply with the information-reporting requirements for 2016 (both for furnishing to individuals and for filing with the IRS). This relief applies to missing and inaccurate taxpayer identification numbers and dates of birth, as well as other information required on the return or statement.
No relief is provided for employers that do not make a good-faith effort to comply with the regulations or that fail to file an information return or furnish a statement by the due dates (as extended above). In determining good faith, the IRS said it will take into account whether an employer made reasonable efforts, such as gathering and transmitting the necessary data to an agent to prepare the data for submission to the IRS, or testing its ability to transmit information to the IRS. In addition, the IRS will take into account the extent to which the employer is taking steps to ensure that it will be able to comply with the reporting requirements for 2017.
If you have any questions, please call the attorney with whom you usually work.