July 26, 2018
The Internal Revenue Service (IRS) has released draft 2018 forms for reporting under Internal Revenue Code (Code) Sections 6055 and 6056. The draft 2018 forms are substantially similar to the final 2017 versions.
Draft Forms 1094-C and 1095-C will be used by applicable large employers (ALEs) to report under Section 6056 for 2018, as well as for combined Section 6055 and 6056 reporting by ALEs who sponsor self-insured plans. A draft Form 1094-B was also released and will be used by entities reporting under Section 6055, including self-insured plan sponsors that are not ALEs. A 2018 draft version of Form 1095-B and draft instructions for these forms have not yet been released.
Individual statements for 2018 (Forms 1094-C and 1095-C) must be furnished to employees no later than January 31, 2019. The 2018 filing deadlines with the IRS are February 28, 2019, and, if filing electronically, April 1, 2019 (as March 31, 2019 falls on a Sunday).
Employers should become familiar with these forms for reporting for the 2018 calendar year. However, these forms are draft versions only, and should not be filed with the IRS or relied upon for filing.
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Burnham Benefits does not engage in the practice of law and this publication should not be construed as the providing of legal advice or a legal opinion of any kind. The consulting advice we provide is intended solely to assist in assessing its compliance with the Patient Protection and Affordable Care Act and other applicable federal and state law requirements, and is based on Burnham Benefit’s interpretation of federal guidance in effect as of the date of this publication. To the best of our knowledge, the information provided herein, and assumptions relied on, are reasonable and accurate as of the date of this publication. Furthermore, to ensure compliance with IRS Circular 230, any tax advice contained in this publication is not intended to be used, and cannot be used, for purposes of (i) avoiding penalties imposed under the United States Internal Revenue Code or (ii) promoting, marketing or recommending to another person any tax-related matter.