Contacts
After a lengthy and unexplained delay, the Internal Revenue Service released drafts of the 2019 Forms 1094-C, 1095-C and their corresponding instructions on November 13, 2019. The forms and reporting obligations are basically unchanged from 2018. There had been speculation that reporting might be streamlined due to the repeal of the individual mandate, but that is not the case.
Minor Changes Only
- All references to the individual mandate were removed, although the reporting requirements tied to the individual mandate remain. These are Form 1095-B and Form 1095-C, Part III.
- Amounts that are annually indexed were adjusted:
- Penalty amount for failing to file or furnish a correct information return cannot exceed $3,339,000 each in a calendar year.
- Affordability percentage updated to 9.86%.
- Due dates for forms:
- Employers must provide Forms 1095-C to full-time employees (and other employees enrolled in self-insured health coverage) by January 31, 2020. The IRS historically extends this deadline to early March, but this hasn’t occurred yet.
- Employers filing less than 250 returns may file paper returns with the IRS by February 28, 2020.
- Employers filing electronically must file with the IRS by March 31, 2020. An employer who files 250 or more returns must file electronically.
The IRS simultaneously released the drafts for the 2019 Forms 1094-B, 1095-B and their corresponding instructions. No major changes were made to the B Forms.
The information contained herein is for general informational purposes only and does not constitute legal or tax advice regarding any specific situation. Any statements made are based solely on our experience as consultants. Marsh & McLennan Agency LLC shall have no obligation to update this publication and shall have no liability to you or any other party arising out of this publication or any matter contained herein. The information provided in this alert is not intended to be, and shall not be construed to be, either the provision of legal advice or an offer to provide legal services, nor does it necessarily reflect the opinions of the agency, our lawyers or our clients. This is not legal advice. No client-lawyer relationship between you and our lawyers is or may be created by your use of this information. Rather, the content is intended as a general overview of the subject matter covered. This agency is not obligated to provide updates on the information presented herein. Those reading this alert are encouraged to seek direct counsel on legal questions. © 2018 Marsh & McLennan Agency LLC. All Rights Reserved.
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