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IRS Announces Filing Extension for 2017 Forms 1095-B and 1095-C

The Internal Revenue Service (IRS) has announced a 30-day automatic extension, in IRS Notice 2018-06, for furnishing 2017 IRS Forms 1095-B (Health Coverage) and 1095-C (Employer-Provided Health Insurance Offer and Coverage) to individuals.  This extends the due date from January 31, 2018 to March 2, 2018.  The extension is almost identical to the extension the IRS provided for submitting the 2016 forms 1094-C and 1095-C in Notice 2016-70.  However, the IRS encourages employers and other coverage providers to furnish the forms as soon as possible.

The notice will not extend the due date for employers, insurers, and other providers of minimum essential coverage to file 2017 forms 1094-B, 1095-B, 1094-C, and 1095-C with the IRS.  The filing due date for these forms remains February 28, 2018 (April 2, 2018, if filing electronically).

Failure to file in a timely manner may subject employers and other coverage providers to penalties.  However, if an entity misses the due date, the Forms should be filed as soon as possible.  The IRS will take this into consideration when ruling on requests for the abatement of any penalties.

Notice 2018-06 also includes language regarding good faith reporting standards.  Essentially this is a continuation of the relief from the 2016 notice in that entities will not be penalized for incorrect or incomplete information if they can demonstrate that good faith efforts were made to comply with the reporting requirements.  The relief applies to incorrect or missing taxpayer ID numbers, dates of birth, and other required information needed to complete the Forms.  The relief with regards to good faith reporting standards will only be extended to entities who make an effort to comply with the reporting requirements.

Any taxpayer who files his/her individual tax return before receiving 2017 Form 1095-B or 1095-C may rely on other information received from their employer or coverage provider for the purpose of completing and filing their individual income tax return.  Therefore, any employers receiving requests for 2017 Forms 1095-C before the extended due date may refer their respective employees to the guidance in Notice 2018-06.  Click Here to Review Notice 2018-06