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Extended Deadline for Form 1095

Last week the Internal Revenue Service (IRS) issued Notice 2016-70 to extend the due date for furnishing Forms 1095-B (Health Coverage) and 1095-C (Employer-Provided Health Insurance Offer and Coverage) by 30 days, January 31, 2017, to March 2, 2017. Filers are not required to submit any request or other documentation to the IRS to take advantage of the extended due date provided by Notice 2016-70. Because this extended deadline applies automatically to all reporting entities, the IRS will not grant additional extensions of time of up to 30 days to furnish Forms 1095-B and 1095-C. As a result, the IRS will not formally respond to any requests that have already been submitted for 30-day extensions of time to furnish statements for 2016. Despite the delay, employers and other coverage providers are encouraged to furnish 2016 statements to individuals as soon as they are able.

The IRS has determined that there is no need for additional time for filing 2016 forms with the IRS. Therefore, Notice 2016-70 does not extend the due date for filing Forms 1094-B, 1095-B, 1094-C or 1095-C with the IRS for 2016. This due date remains February 28, 2017 (March 31, 2017, if filing electronically). Because these due dates are unchanged, potential extensions of time for filing information returns are still available under the normal rules by submitting a Form 8809. The notice also does not affect the rules regarding additional extensions of time to file under certain hardship conditions.

Because of the extended furnishing deadline, some individual taxpayers may not receive a Form 1095-B or Form 1095-C by the time they are ready to file their 2016 tax returns. Taxpayers may rely on other information received from their employer or other coverage provider for purposes of filing their returns, including determining eligibility for an Exchange subsidy and confirming that they had MEC for purposes of the individual mandate.

Please read our full Legislative Brief for more information.