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By Thomas B. Henke

On December 28, 2015, the IRS released Notice 2016-4, which extended the deadlines for employer and insurer reporting under the Affordable Care Act. The deadlines have been delayed as follows:


* While only insurers and employers with more than 250 1095 statements are required to file electronically, the IRS does encourage all employers to submit electronically, even if the 1094 transmittal includes fewer than 250 statements.

Notice 2016-4 also included relief for individuals who do not receive a 1095-B or 1095-C, as applicable, by the time they file their 2015 tax returns. If such individuals relied upon information from a health care exchange or their employer to determine their eligibility for premium tax credits in 2015 (or whether they had minimum essential coverage), the IRS generally will not require them to amend their 2015 returns or send in the 1095-B or 1095-C upon receipt.


Please contact a member of Fredrikson & Byron’s Compensation Planning & Employee Benefits Group should you have any questions on the application of this guidance to your business or group health plans.

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