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IRS Issues Extensions & Good Faith Transition Relief for 2017 ACA Reporting

Friends and Clients:

We wanted to pass along welcome news from the IRS regarding ACA reporting requirements under Code Sections 6055 and 6056 for the 2017 calendar year (to be completed in 2018). As with prior years, the IRS has extended the deadline for furnishing to individuals the 2017 ACA reporting forms (i.e., Forms 1095-B and 1095-C) from January 31, 2018 to March 2, 2018. Note, however, that the Notice does not extend the deadline for filing the ACA reporting forms (i.e., Forms 1094-B, 1095-B, 1094-C, and 1095-C) with the IRS. This deadline remains February 28, 2018, if not filing electronically, or April 2, 2018, if filing electronically.

Perhaps the most important aspect of the Notice is the extension of the “good-faith” transition relief from Section 6721 and 6722 penalties with respect to 2017 ACA reporting. In general, this relief applies to incorrect or incomplete information reported on the return or statement if the employer or other reporting entity can show it has made good faith efforts to comply with the ACA reporting requirements. The good-faith transition relief does not apply with regard to penalties for late or missed filings.

You may view a copy of the IRS Notice at the following link:

Text of IRS Notice 2018-06: Extension of Due Date for Furnishing Statements and of Good-Faith Transition Relief under Code Sections 6721 and 6722 for Reporting Required by Code Sections 6055 and 6056 for 2017 (PDF)

If you have any questions or would like additional information, please reach out to a member of Maynard Cooper’s Employee Benefits and Executive Compensation team.

This Client Alert is for information purposes only and should not be construed as legal advice.  This information is not intended to create, and receipt of it does not constitute, a lawyer-client relationship.  

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