Forms 1094C and 1095C Final Instructions for 2017

The IRS has released the final instructions for 2017 for Form 1094C and Form 1095C, required of all employers subject to the employer mandate. As anticipated, there are no major changes on either form. The only change for this year is the removal of the Section 4980H transition relief that was available to certain employers for 2016.

Employers subject to the employer mandate under the ACA should move forward with ensuring they're prepared to complete, distribute and file Form 1094C and Form 1095C.

Individual Mandate Update

In prior years, individual tax returns that didn't include the health coverage information on the Form 1040 were still processed. The IRS has stated it won't accept electronically filed tax returns where the taxpayer doesn't address the health coverage requirements portion of the ACA for the 2017 tax returns filed in 2018. To file, an individual must indicate whether they had coverage, had an exemption or will need to make a shared responsibility payment. Additionally, paper returns that don't have that section completed may not be processed pending the receipt of the additional health coverage information. That also means any refunds may also be delayed for those individuals. To avoid processing delays, individuals should be prepared to report their health coverage information for the 2017 calendar year. As of the time of this notice, individuals will still not be required to submit their Form 1095, however, they should still be kept with individuals’ tax documents.

Information contained herein is not intended to constitute tax or legal advice and should not be used for purposes of evading or avoiding otherwise applicable regulatory responsibilities as issued by the federal or state government(s) and/or taxes owed under the Internal Revenue Code. You are encouraged to seek advice from your legal or tax advisor based on your circumstances.