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IRS Releases Draft Instructions for 2015 1094-C and 1095-C Series Forms Released

Story Content Provided by SyncStream Solutions on 8/28/15

On August 6th the IRS released draft instructions for the 2015 1094-C and 1095-C Forms that Applicable Large Employers are required to submit in early 2016. There were several small changes made to the Forms, but nothing substantive has changed. Small changes include:

  • Form 1094-C moved Line 19 (Is this the Authoritative Transmittal for this ALE Member?) into Part I of the form
  • Line 23 in Part III of the 1094-C form now allows for an entry in the "All 12 Months field" for the number of Full-Time Employee Count for ALE Member
  • Form 1095-C was revised to include a first month of the plan year indicator (which is not required for the first year of reporting), and
  • A Continuation Sheet for Covered Individuals (Part III of the Form) was added

Extension Process
As SyncStream anticipated the IRS has also included information about an extension process for employers who will not be ready to file required Forms to the IRS in early 2016.

30 Day Extension
Employers can receive an automatic 30-day extension by completing Form 8809, Application for Extension of Time to File Information Returns. The Form may be submitted in paper format

  • Special rules apply that increase the per-statement and total penalties if there is intentional disregard of the requirement to furnish a payee statement. Note that while the penalty amounts have been increased, the draft instructions reiterate that penalties will not be imposed on a filer for reporting incorrect or incomplete information if the filer can show that they made good faith efforts to comply with the information reporting requirements of 2015.

SyncStream's Conclusions: Overall these draft instructions have not changed much for what employer's will be required to do. The most significant changes are related to penalties and the extension processes that have been identified in the instructions. As we recognize the extension process may be extremely important to some employers coming onto our system later in the 2015. While it is Sync Stream's intention to support these extension procedures, SyncStream would encourage all partners and employers to continue their preparations for 2015 reporting without delay. We will keep our partners updated and informed of that support so they will be able to relay that information to their customers.

For more information about how this can impact your clients, contact your
FNA Representative today.
FNA Insurance Services, Inc.
1000 Woodbury Road, Suite 403 • Woodbury, NY • 11797 (516) 352-7000 • Fax (516) 352-3135
180 River Road • Summit, NJ • 07091 (973) 257-5558 • Fax (973) 257-5557