Large employers and employers with self-funded insurance plans still have a requirement to file their 2016 1094/1095 forms in a timely manner. The non-deductible penalties for not filing these forms range from $260 to $520 per form.
On November 18, 2016, the IRS announced via IRS Notice 2016-70 that it has issued transition relief for filing 2016 ACA Forms 1095-B and 1095-C, which extends the due date from January 31, 2017, to March 2, 2017. Filers must continue to file Forms 1094-B, 1095-B, 1094-C and 1095-C to the IRS by February 28, 2017, if filing paper and March 31, 2017, if e-filing.
Notice 2016-70 also extends the transition relief for sections 6721 and 6722 penalties if a good faith effort is made in preparing the forms. This penalty relief is the same as it was for the 2015 forms. The penalty relief does not apply to a failure to file the forms in a timely manner. This notice applies only to 2016 forms and not to any future years. The IRS does not intend to extend this relief for the 2017 ACA filing period.
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