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The ACA states that Applicable Large Employers (ALEs) are required to furnish forms 1095-B (if self-insured) or 1095-C (if fully-insured) to their employees by January 31st. On November 29, 2018, the IRS extended that deadline to March 4, 2019, for the 2018 reporting period. This is not unusual. In past years, the IRS extended deadlines for the 2016 and 2017 reporting periods as well.
Keep in mind that the IRS did not extend the deadline for ALEs to file forms 1094-B, 1094-C, 1095-B and 1095-C with the IRS. Paper filers must file those forms by February 29, 2019, and electronic filers must file by April 1, 2019.
While the IRS has granted an extension to March 4, 2019, for distributing forms 1095 to employees, ALEs may still want to furnish those forms before the deadline if possible. This will allow employees who may want to file their taxes early, to do so with the needed forms.
The IRS has anticipated the scenario where the employee wishes to file their return prior to receiving their form 1095. In this situation, the IRS says, in its Notice 2018-94 that:
“Taxpayers do not need to wait to receive Forms 1095-B and 1095-C before filing their returns and 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 under section 36B and confirming that they had minimum essential coverage for purposes of sections 36B and 5000A. Although taxpayers need not send the other information relied upon to the Service when filing their returns, they should keep that information with their tax records.“
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