Delayed 1095-B and 1095-C Filings

Notice 2016-04 delays the due dates for the 2015 1095-B and 1095-C reporting requirements, both furnishing to individuals and filing with the IRS, for insurers, self-insuring employers and certain other providers of minimum essential coverage. The extended due date is March 31, 2016, which will impact many individual tax return filings in determining whether a taxpayer has minimum essential coverage or qualifies for the premium tax credit when they are offered employer-sponsored coverage by an applicable large employer.

The IRS has instructed that individuals may rely on information received by their coverage provider to determine if they have minimum essential coverage, which would normally be provided on Form 1095-B. It is advisable that you utilize the same information provided to the taxpayer other than Form 1095-B to determine if the taxpayer has minimum essential coverage.

In addition, individuals may also rely on information from their employers to determine if they were qualified to receive a premium tax credit based on their insurance being affordable or providing minimum value, which would normally have been provided on Form 1095-C. It is advisable that you utilize the same information provided to the taxpayer other than Form 1095-C to determine if the taxpayer qualified for the premium tax credit.

Upon reliance of either of the above, depending on what is necessary, a taxpayer does not need to amend his or her tax return once Form 1095-B or 1095-C is received.

This does not impact Form 1095-A issued by the marketplace; therefore, taxpayers should generally receive this by early February at the latest.

Please provide proof of health insurance with your 2015 tax information!

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