The IRS Extends Deadlines for Providing and Filing 2015 Forms 1095-C and 1094-C

Today, in Notice 2016-4, the IRS has provided a significant time extension for providing Forms 1095-C to employees and for filing Form 1094-C and Forms 1095-C with the IRS. The IRS also has made concessions for employees who do not receive this information before they file their individual federal tax returns.

Background. Under Sections 6055 and 6056 of the Internal Revenue Code of 1986, as amended, each Applicable Large Employer Member (“ALEM”) is required to:

To Employees:
- By February 1, 2016, provide a copy of Form 1095-C to each full-time employee (“FTE”) and each non-FTE who is covered under the ALEM’s group medical plan.
To the IRS:
- By February 29, 2016, file with the IRS a paper copy of Form 1094-C, along with a copy of all employees’ Forms 1095-C; or
- By March 31, 2016, file with the IRS an electronic copy of Form 1094-C, along with a copy of all employees’ Forms 1095-C.

The IRS indicated that (i) an employer could apply for a 30-day extension of the February 1 date, which the IRS may or may not grant; and (ii) the IRS would permit an automatic 30-day extension of the date for filing with the IRS.

Extension of the 2015 Reporting Dates. The IRS has issued an automatic extension of all of the original dates by which Forms 1095-C and 1094-C must be provided and/or filed. This extension applies only to the reporting for 2015 due in 2016, and will not apply to any future years. An ALEM may file the forms with the IRS any time before these extended dates, beginning in January 2016. The extended dates are:

Form Recipients	Original Dates	Extended Dates
Employees	February 1, 2016	March 31, 2016
IRS – Paper Copy	February 29, 2016	May 31, 2016
IRS – Electronic Copy	March 31, 2016	June 30, 2016

No Additional Extensions for 2015 Reporting. The IRS has stated that, because it is providing these extensions for the 2015 reporting due in 2016, additional extensions will not be permitted for that year.

Individual Tax Reporting. The IRS previously stated that individuals will be required to file with their individual federal tax returns copies of the Forms 1095-C that they receive from their employers. Because individuals now may file their tax returns before they receive these forms, the IRS has waived this filing requirement for the 2015 tax return. Instead, individuals may rely on information they receive from other sources in preparing their tax returns, and they are required to maintain copies of their Forms 1095-C in their tax records.

Impact. These extensions may provide employers with the time they need to complete the forms for 2015 and help ensure their accuracy.

Contact Information. For more information from Mazursky Constantine, please contact Don Mazursky (404.888.8840), Kelly Meyers (404.888.8838), or Alex Smith (404.888.8839). For additional information from VCG Consultants, please contact Leslie Schneider (770.863.3617).