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Filing deadline extended for 2016 Forms 1095 B & C

In a show of understanding for the complexities faced under ACA reporting, in Notice 2016-70, the IRS has extended the filing deadline for the 2016 information reporting requirements under ACA (Affordable Care Act) for insurers, self-insuring employers and certain other providers.

health care, Obamacare, Affordable Care Act, filing deadline, Forms 1095The IRS extended the due date for furnishing the 2016 Form 1095-B and the 2016 Form 1095-C to individuals to March 2, 2017. The original due date was January 31, 2017.

The extension of the due date applies only to Code Sec. 6055 and Code Sec. 6056 information statements for calendar year 2016 that are filed and furnished in 2017.

No application or submission of documentation is required to receive this automatic extension. However, the IRS encourages employers and other coverage providers to furnish the information returns to their employees as soon as they are able.

No automatic extension for furnishing forms to IRS. Notice 2016-70 does not automatically extend the due date for filing the applicable forms with the IRS. The 2016 Forms 1094-B, 1095-B, 1094-C or 1095-C, remain due February 28, 2017, if not filing electronically, or March 31, 2017, if filing electronically.

However, the normal rules for requesting an extension under Reg. § 1.6081-1 and Reg. § 1.6081-8T by submitting a Form 8809 (Application for Extension of Time to File Information Returns) remain available. These provisions and those regarding additional extensions of time to file aren’t affected by Notice 2016-70.

Due to the above change, individuals may not receive a Form 1095-B or Form 1095-C by the time they are ready to file their 2016 tax returns. As was the case last year, taxpayers may rely on other information received from their employer or other coverage provider for purposes of filing their tax returns including determining eligibility for the premium tax credit under Code Sec. 36B and confirming that they had minimum essential coverage for purposes of Code Sec. 36B and Code Sec. 5000A.

Melinda Nelson, CPA