6055 and 6056 Reporting Due Dates Extended

With the deadline for furnishing Forms 1095-B and 1095-C to individuals rapidly approaching, the IRS issued a surprise this afternoon (Notice 2016-4). The IRS notice officially extends the due dates for filing the 2015 forms and for providing those forms to the required individuals.

Applicable large employers and health insurance issuers now have nearly two additional months to issue Forms 1095-B and 1095-C to individuals. Those forms must now be distributed by March 31, 2016 (rather than the original due date of February 1).  The deadline for filing the forms with the IRS (1094-B, 1094-C, 1095-B and 1095-C) has been extended three months. If filing by mail, the new deadline is May 31, 2016. If filing electronically, the new deadline is June 30, 2016.

2015 Report

Original Deadline

Extended Deadline  

Forms Sent to Individuals

  • 1095-B
  • 1095-C

2/1/2016

3/31/2016

Forms Filed with IRS

  • 1094-B and 1095-B
  • 1094-C and 1095-C

2/29/2016 – Paper

3/31/2016 – Electronic

5/31/2016 – Paper

6/30/2016 – Electronic

Please note that this delay is specific to forms relating to the 2015 calendar year that will be filed in early 2016 (and presumably the previous deadlines will go back into effect in 2017). Employers who fail to meet the extended deadlines may still be subject to penalties, although the IRS stated that penalties for late returns may be abated for reasonable cause such as difficulties beyond the entity’s control in gathering and transmitting required data.  As a reminder, the penalty for failing to submit a required return is $250 for each return.

The original deadline for furnishing Form 1095-B and Form 1095-C coincided with the deadline for furnishing the Form W-2 to employees and was intended to aid taxpayers in filing their federal tax returns. The IRS has acknowledged that this extension could cause problems for some individuals who will not have received their forms prior to submitting their tax returns, but that such individuals may rely on other information received from coverage providers and will not need to file an amended return upon receipt of the Form 1095-B or Form 1095-C or any corrections.

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About Dawn Kramer

Dawn is an attorney and Certified Employee Benefit Specialist (CEBS) in J.W. Terrill’s Consulting Services department. She advises clients on legal and regulatory issues affecting their employee benefit plans.

View all posts by Dawn Kramer

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