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Happy New Year! IRS Gives Employers More Time For ACA Reporting!

Labor & Employment Alert John L. Barlament, Sarah L. Fowles

On December 28, 2015, the IRS issued guidance extending the deadline for providing new Affordable Care Act tax forms to employees and to the IRS. This guidance provides a bit of breathing room to employers with 50 or more employees. However, it does not remove the reporting obligations; large employers still need to focus quickly on these new rules.

Chart Comparing Deadlines. The old and new deadlines for the 1094 / 1095 forms are noted below.


What if New Deadlines Cannot be Met? Even if an employer cannot meet the extended deadlines, the IRS still recommends that employers furnish and file the forms. The IRS notes that it will take the late furnishing and filing into consideration when determining whether to reduce penalties for reasonable cause. In addition, the IRS will take into consideration whether an employer made reasonable efforts to prepare for reporting.

For more information about the Affordable Care Act's new tax reporting obligations, please contact one of the authors of this article or your Quarles & Brady attorney.