On more than one occasion since passing the Affordable Care Act (“ACA”), the IRS has given some type of early holiday “gift” to alleviate pending compliance concerns for employers. One of the most significant of these occurred in late December 2015, when the IRS extended the mandated filing periods for Forms 1094/1095, which gave employers more time to comply with the ACA’s new reporting obligations. Employers were still coming to grips with reporting health insurance coverages offered during the 2015 taxable year and the litany of new codes used to determine if the employer had adequately complied with Code Section 4980H’s employer shared responsibility requirements. At that same time, the IRS also communicated that employers would not be penalized for filing incorrect or incomplete Forms 1094/1095 if the forms were actually filed by the extended deadlines and filers could show they “made good faith efforts to comply with the information reporting requirements for 2015.”
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