The IRS released Notice 2016-4, which grants an automatic extension of the due dates for the 2015 1094 and 1095 forms for all of those required to file, both insurers and employers. The IRS has said it is ready to accept the filings but realizes insurers and employers need more time to gather the information necessary to prepare the forms. The IRS is therefore encouraging employers to file as soon as they are ready.
The extended due dates are as follows:
The due date for furnishing the individual/employee a copy of Form 1095-B or 1095-C has been extended from February 1, 2016, to March 31, 2016.
The due date for filing the Forms 1094/1095-B or 1094/1095-C with the IRS on paper has been extended from February 29, 2016, to May 31, 2016.
The due date for filing the Forms 1094/1095-B or 1094/1095-C with the IRS electronically has been extended from March 31, 2016, to June 30, 2016.
Because of the extensions of the due dates, the automatic extensions permitted in the regulations will not apply to the extended due dates. The dates above are the final permitted due dates.
Notice 2016-4 also provides guidance for individuals who might not receive their Forms 1095-B and 1095-C by the time they file their personal income tax returns. The forms do not need to be attached to individual tax returns, so individuals are permitted to prepare their returns prior to receiving the forms and are not required to amend their tax returns if the information they used to prepare their return is different from what is reported on the Forms 1095-B/C they receive.
Wipfli is in the process of preparing Forms 1094/1095 for clients that have engaged us to do so and will provide the forms for employees as soon as they are complete. If you have any questions or need assistance with your filing, please contact your Wipfli relationship executive.