Alert / Employee Benefits
IRS extends 1095-C distribution deadline & good-faith relief

A holly, jolly extension: IRS continues annual trend of extending 1095-C distribution deadline and good-faith relief

In what is seemingly becoming an annual holiday tradition, the IRS announced this afternoon a brief reprieve for employers hustling to prepare and distribute 2018 Forms 1095-C to employees by Jan. 31, 2019. The IRS will give employers until March 4, 2019, to distribute the forms to employees. The delay also applies to insurers and others issuing Form 1095-B to covered individuals.

The delay is automatic and does not depend on the employer or insurer asking for an extension. As a result of this automatic 30-day extension, the 30-day extension that would normally be available upon a showing of good cause is not available. That is, the March 4 deadline is a hard deadline.

There is no delay, however, in the deadline to file the forms with the IRS. Forms are due to the IRS by Feb. 28, 2019, for employers filing on paper, and by April 1, 2019, for employers e-filing their forms. Employers filing at least 250 Forms 1095-C with the IRS must do so electronically unless they obtain a waiver from the IRS. Employers may obtain a guaranteed 30-day extension from the deadlines for filing with the IRS by submitting Form 8809 on or before those deadlines.

In addition, the IRS said it will continue to apply to 2018 filings the same "good faith" approach to employer Affordable Care Act filings that applied to filings for the 2015, 2016 and 2017 calendar years. This relief applies only to incorrect and incomplete information reported on Form 1095-C or 1095-B, and not to a failure to timely furnish or file the forms; although, the IRS may excuse penalties for failing to furnish or file upon a showing of reasonable cause.

Not legal advice: Nothing in this Alert should be construed as legal advice. Lockton may not be considered your legal counsel, and communications with Lockton's Compliance Services group are not privileged under the attorney-client privilege.


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