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ARTICLE · 03 JANUARY 2023

Permanent Extension To The ACA Reporting Deadline

Seyfarth Shaw LLP
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Recently the U.S. Treasury Department (Treasury) and Internal Revenue Service (IRS) issued regulations (the "Final Regulations") which finalized previously proposed relief for furnishing...

United StatesEmployment and HR
Joy Sellstrom
Joy Sellstrom
Sarah N. Magill
Sarah N. Magill
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Seyfarth Synopsis: Recently the U.S. Treasury Department (Treasury) and Internal Revenue Service (IRS) issued regulations (the “Final Regulations”) which finalized previously proposed relief for furnishing Forms 1095-B and 1095-C to individuals. Notably, the Final Regulations provide a permanent 30-day extension to the due date for furnishing Form 1095-C to individuals. This extension was previously granted in the 2021 final instructions for completing Forms 1094-C and 1095-C for 2021 (see our blog here) issued in December 2021.

As background, employers with 50 or more full-time employees (including full-time equivalent employees) in the previous year (“applicable large employers” or “ALEs”) use Forms 1094-C and 1095-C to report information about offers of health coverage and enrollment in health coverage for their employees. Form 1094-C is used to report information for each ALE Member and to transmit Forms 1095-C to the IRS. Each employee for whom reporting is

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