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IRS Forms 1094-C/1095-C Draft Instructions Released

The IRS recently released draft instructions for Forms 1094/1095 that correspond with the draft Forms 1094/1095 the IRS released in July (please see our prior blog post on the draft forms?áhere). Highlights of the changes and clarifications in the draft instructions for Forms 1094/1095 include:

  • Certain transition relief available in 2015 remains available for non-calendar year plans for the portion of the 2015 plan year that ends in 2016;
  • Certain coding used in Forms 1094-C/1095-C has been reserved for 2016; and
  • Retirees who separated from employment should be reported the same as COBRA participants who separated from employment.

Filing Dates and Extensions:

To the IRS. The 2016 Form(s) 1094-C and accompanying Forms 1095-C must be filed electronically with the IRS by March 31, 2017 (February 28, 2017 if paper filing is used). An automatic 30-day extension is available if filed no later than the due date. Another 30-day extension may be requested for cause.

To Employees/Individuals. The 2016 Forms 1095-C must be provided to employees by January 31, 2017. A 30-day extension may be requested for cause.

The draft instructions for Forms 1094-C/1095-C are available?áhere. The draft instructions for Forms 1094-B/1095-B are available?áhere.

The lawyers of our Employee Benefits and Executive Compensation Practice Group are readily able to assist companies on a nationwide basis with implementing sophisticated benefit plans and providing answers to their most challenging compensation issues. Additionally, our lawyers are well aware of the daily employee benefits challenges facing companies of all sizes and are capable of helping in-house lawyers and human resources personnel with the day-to-day advice and guidance necessary to properly administer employee benefits plans.

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August 2016