IRS Extends Deadlines for Section 6055 and 6056 Reporting

On Dec. 28, 2015, the IRS released IRS Notice 2016­4, which delays Sections 6055 and 6056 reporting for the 2015 reporting year. Forms 1095­B and 1095­C must now be distributed to employees by March 31, 2016, as opposed to the original due date of Feb. 1, 2016. If filing by paper, Forms 1094­B, 1095­B, 1094­C and 1095­C must be filed with the IRS by May 31, 2016 (changed from Feb. 29, 2016). If filing electronically, the forms are due to the IRS by June 30, 2016 (changed from March 31, 2016). The extended deadlines apply to all filers automatically. In summary, the deadline for distributing forms to employees has been extended two months, while the filing deadline with the IRS has been extended three months.

 The original due dates were aligned so that individual taxpayers could use the information contained in the forms to file their individual tax returns. Specifically, the information is needed by individuals to help determine whether they were eligible for the premium tax credit or subject to the individual mandate. The IRS has granted this automatic extension due to the fact that insurers, self­insuring employers and other providers of minimum essential coverage need additional time to adapt and implement systems and procedures to comply with the reporting requirement. As a result of this delay, if individuals have not received the information by the time they file their individual tax return, they may rely upon other information received from employers or coverage providers when filing their returns. They need not amend their returns once they receive the forms, but they should keep them with their tax records.

The IRS reinforced that an employer should make a good­faith effort with reporting. If an employer does not comply with the extended deadlines, the employer could be subject to penalties.

IRS Notice 2016-4