IRS delays due date for delivery of form 1095-C to employees from February 1, 2016 to March 31, 2016.
The IRS also delayed filing due dates for Form 1094-C, the Employer Transmittal Return, to May 31, 2016 if filed by paper return, or June 30, 2016 if filed electronically.
The IRS also provided the following guidance for individuals who opted out of employer sponsored health insurance and instead purchased subsidized coverage through the healthcare marketplace exchanges (i.e. Covered California) and who file their individual tax returns before receiving form 1095-C.
“For 2015 only, individuals who rely upon other information received from employers about their offers of coverage for purposes of determining eligibility for the premium tax credit when filing their income tax returns need not amend their returns once they receive their Forms 1095-C or any corrected Forms 1095-C. Individuals need not send this information to the Service when filing their returns but should keep it with their tax records.”
In short, the IRS will take the individual taxpayer at their word that they received information from the employer that the coverage offered by their employer was not affordable and/or did not meet the minimum essential coverage requirements and therefore were eligible to receive a subsidy to purchase insurance through the exchanges.
Payality will work with each affected client to determine if they wish to delay preparation and delivery of form 1095-C to employees.
A complete copy of the IRS Notice can be found at the following link: https://www.irs.gov/pub/irs-drop/n-16-4.pdf
