Benefits Blog

In early August the draft instructions were released for the 2016 Forms 1094-C and 1095-C, which will be filed in Q1 2017. This post provide an overview of the changes to the Form 1095 employee information report, provides helpful reminders and point out things the IRS emphasized in the instructions to the Form 1095-C. (For important revelations from the draft instructions for the 2016 Form 1094 employer transmittal, click here.)Deadline LoomingFirst, and most importantly, the deadline to furnish the 2016 Form 1095-C statement to employees is January 31, 2017. This is two months earlier than the generous extension granted by the IRS for the 2015 Forms. Considering the Form 1095-C is the bulk of the work, an employer must be on top of its Form 1095-C reporting game in 2016. If you can spare the resources, it is a good idea to begin updating your Form 1095-C database with the data you've gathered so far this year through payroll and benefits administration systems.

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In early August the draft instructions were released for the Forms 1094-C and 1095-C for 2016. While not much has changed, there are some differences in the Forms compared to 2015, and the IRS emphasized certain areas that many filers struggled with in 2015. This article is intended to provide an overview of the changes, provide helpful reminders, and point out things the IRS emphasized in the instructions to the Form 1094-C. Different 1094 Deadline in 2017 for 2016 DataFirst, and most importantly, the deadline for the Form 1094-C will be three or four months earlier in 2016 compared to 2015. The IRS has been clear that it does not plan to issue an extension as it did for the 2015 Forms. Therefore, the filing deadline for non-electronic filers for the 2016 Form 1094-C is February 28, 2017. The filing deadline for electronic filers for the 2016 Form 1094-C is March 31, 2017.

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Ambiguity Resolved! I recently caught up with a knowledgeable person at the IRS regarding an employer’s solicitation obligations for an incorrect taxpayer identification number (TIN). A great many employers who submitted Forms 1095-C received an AIRTN500 error message for at least one Form 1095-C. Certain employers received the AIRTN500 error message on 10 to 15 percent of the Forms 1095-C submitted to the IRS. This presented the apparent and daunting task of soliciting hundreds, if not thousands, of TINs following the procedures discussed in the regulations at section 301.6724-1. (This is due to conflicting views promoted by various pieces of IRS guidance, discussed in part 1 of this series.) However, the IRS has informed this author that no solicitation effort is triggered by an AIRTN500 error message for an incorrect TIN.

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BackgroundOn August 2, 2016, the IRS published proposed regulations, which, among other things, attempt to clarify the confusion regarding an employer's obligation to solicit taxpayer identification numbers (TIN). This is the government’s third attempt to clarify the issue since the ACA was enacted. The IRS made its first attempt in the preamble to the final regulations for employer reporting.

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