IRS Extends ACA Deadline

In Notice 2018-6, the IRS has extended the due date for furnishing to individuals filing the 2017 Form 1095-B, Health Coverage, and the 2017 Form 1095-C, Employer-Provided Health Insurance Offer and Coverage, from January 31, 2018 to March 2, 2018. There are no further extensions allowed for providing these forms to individuals. The notice did not extend the due date for filing these forms (1094-B, 1095-B, 1094-C, and 1095-C) with the IRS. Those due dates remain February 28, 2018, if not filing electronically, and April 2, 2018, if filing electronically. However, a 30-day extension for filing these forms with the IRS is still available by filing Form 8809, Application for Extension of Time to File Information Returns.

In addition, the notice extends the transition relief from certain penalties to reporting entities that can show that they have made good faith efforts to comply with the information reporting requirements for 2017 (both for furnishing to individuals and for filing with the IRS) for incorrect or incomplete information reported on the return or statement. This relief applies to missing and inaccurate taxpayer identification numbers and dates of birth, as well as other information required on the return or statement. No relief is provided in the case of reporting entities that do not make a good faith effort to comply with the regulations, or that fail to file an information return or furnish a statement by the due dates.

The IRS has also provided guidance to individuals who might not receive a Form 1095-B or 1095-C by the time they file their 2017 tax returns due to the extension in Notice 2018-6. Taxpayers may rely on other information received from their employer, or other coverage provider, for purposes of filing their returns, including determining eligibility for the premium tax credit and confirming that they had the required minimum essential coverage. Taxpayers do not need to wait to receive Forms 1095-B and 1095-C before filing their returns.

About the Author(s)

Mike Walston is a Principal in HBK's Hermitage office. He has been with HBK for three years, focusing on tax compliance and consulting as well as financial statement compilation and review engagements. Mike completed the Checkpoint Learning Health Care Reform Certificate Program sponsored by Thomson Reuters and has been leading HBK’s Affordable Care Act niche since the fall of 2015. Before joining HBK, Mike spent eight years with Deloitte Tax LLP in Cleveland, Ohio. His tax experience includes compliance and consultation for both public and private companies, Estate and Gift tax matters, Trust taxation, and state and local tax compliance. He has extensive experience working with partnerships, S corporations, and consolidated corporations.

Mike is a member of the AICPA and a Certified Public Accountant for both the State of Ohio and State of Pennsylvania.

Hill, Barth & King LLC has prepared this material for informational purposes only. Any tax advice contained in this communication (including any attachments) is not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or under any state or local tax law or (ii) promoting, marketing or recommending to another party any transaction or matter addressed herein. Please do not hesitate to contact us if you have any questions regarding the matter.