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The due date for filing 2016 Forms 1095-B and 1095-C has been extended by 30 days according to Notice 2016-70, issued by the Department of the Treasury and Internal Revenue Service on November 18.

This extends the deadline for furnishing these forms from January 31, 2017 to March 2, 2017, but does not apply to the corresponding forms. Those due dates remain February 28, 2017 for forms not filed electronically and March 31, 2017 for forms filed electronically.

For employers who have shown they have made good faith efforts to report on or provide individuals with necessary information as required under sections 6055 and 6056, Notice 2016-70 also extends the “good faith effort” transition relief. The standard applies to the initial furnishing of statements to individuals, as well as filing for inaccurate or incomplete information reported on the return or statement with the IRS. This includes incorrect taxpayer identification numbers and dates of birth, among other information.

In order to determine good faith, the IRS will determine whether the employer or coverage provider has suitably made an effort to prepare the necessary information and provide it to individuals. Additionally, the IRS will determine if the employer or coverage provider is taking steps to ensure that it will be able to comply with 2017 reporting requirements, which are due in early 2018.

If you would like more information or have questions or concerns, please contact Gauri Gupta at or (732) 832-7997 x2008.