Last year, employers had extra time to complete their Section 6055 and 6056 reporting, thanks to transition relief from the IRS. This year, it’s unlikely that the IRS will provide any relief from the normal deadlines.
This means that employers will need to act quickly in order to distribute the required forms to employees in January 2017 and then file returns with the IRS on time.
The 2016 reporting deadlines for specific forms are as follows:
Jan. 31, 2017—Forms 1095-B and 1095-C due to employees (to be postmarked, if mailed, or sent by email if applicable conditions are met)
Feb. 28, 2017—Forms 1094-B, 1095-B, 1094-C and 1095-C due to the IRS if filing on paper
March 31, 2017—Forms 1094-B, 1095-B, 1094-C and 1095-C due to the IRS if filing electronically
Any employer filing 250 or more information returns during the calendar year must file these returns electronically, unless the employer obtains a waiver. For employers filing fewer than 250 returns, electronic filing is voluntary.
Employers that need extra time to file returns with the IRS can request an extension by completing IRS Form 8809 before the filing deadline. Additional extensions may be available if certain hardship conditions apply.
Employers can also request an extension of time to furnish employee statements by sending a letter to the IRS. More information about extensions is available in the instructions for each form.
Filing or furnishing late or incomplete returns can subject you to IRS penalties. In some cases, the IRS may not impose penalties if the failure was due to reasonable cause. However, the more generous transition relief for employers making a good faith effort to comply does not apply to 2016 reporting.
Being prepared and organized can help you meet earlier deadlines for 2016 ACA reporting and avoid potential penalties or other problems.