The IRS has once again extended the deadline for furnishing to
employees the applicable tax forms required by the Affordable Care
Act (ACA), and will continue to provide employers with penalty
relief if they make good-faith efforts to comply with the ACA's
tax reporting requirements. Unfortunately, unlike last year, the
IRS did not extend the deadline for filing the applicable tax forms
with the IRS.
As background, for the first time last year employers were
required to perform ACA tax reporting. This generally required
large employers to complete a Form 1095-C for each full-time employee and all
other employees enrolled in self-insured health coverage (if the
employer sponsors a self-insured health plan), and furnish the Form
1095-C to the employee and file copies of the Forms 1095-C with the
IRS. Because it was the first year of reporting, the IRS provided
that it would not impose penalties if the employer made good-faith
efforts to comply. Last year, the IRS
