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Last Year for Leniency on Forms 1095-C

In keeping with prior years, the IRS has extended the due date for providing the 2020 Forms 1095-B and C to individuals until March 2, 2021. These forms are required for compliance with the Affordable Care Act (?Ç£ACA?Ç¥). In Notice 2020-76, the IRS also extended the good-faith transition relief for penalties related to incomplete or incorrect Forms 1095-B and C to 2020. Notice 2020-76 also states that this is the last year for which the IRS intends to provide this type of good-faith relief. This relief was especially helpful for employers who received ACA employer penalty notices and determined that the penalty notices were related to reporting errors on their Form 1095-C. Employers should thus ensure that all software errors and glitches that resulted in incorrect coding on Forms 1095-C are resolved before the 2021 reporting is due. Notice 2020-76 is available here.

The Few, The Proud, The Patent-Eligible Software Claims

The Few, The Proud, The Patent-Eligible Software Claims

It is no secret that it is difficult for software technology patent claims to be deemed subject matter eligible under 35 U.S.C. ?º 101 on appeal, as only a handful of cases involving software technology have passed ?º 101 scrutiny by the Federal Circuit since the Supreme Court?ÇÖs decision in Alice v. CLS Bank[1]: Until recently, there have been only three such cases: DDR Holdings, LLC v. Hotels.com, L.P.,[2] Enfish LLC v. Microsoft Corp.,[3] and BASCOM Global Internet Services, Inc. v. AT&T Mobility LLC.[4] However, now a fourth case may be added to those ranks. On September 13, 2016, the Federal Circuit decided McRO, Inc. v. Bandai Namco Games America Inc.,[5] ruling that claims directed to automating part of a preexisting 3-D animation method were patent-eligible under ?º 101. Below is a review of the McRO case facts, the legal reasoning of the Federal Circuit in reaching its conclusion, and… Continue Reading

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