ACA Reporting – Did You Know!?!?

While you likely know the IRS requires any Applicable Large Employer that creates 250 or more Forms 1095-C to file those forms electronically with the IRS, we came across some interesting information recently that may be of interest to many of our (and your) clients. Did you know…the 2015 instructions for the 1094 & 1095 forms propose a waiver from the requirement to file returns electronically? We didn’t think so. Not many people are aware of this potential option. To receive a waiver, employers must submit Form 8508 [Request for Waiver From Filing Information Returns Electronically], and this form must be filed at least 45 days before the due date of the returns. Employers cannot apply for a waiver for more than one tax year at a time, and must reapply at the appropriate time for each year in which a waiver is required. Any approved waivers should be kept for the reporting entity’s records only. A copy of an approved waiver should not be sent to the service center where paper returns are filed. In looking Form 8508 over, it appears there are two ways an employer can obtain this waiver. The first is that this must be the first time an employer has requested a waiver…which, by virtue of this being year 1 for 99.9% of US employers filing Forms 1094/1095, allows an employer to achieve this waiver. The second (to be considered in subsequent years), requires the employer to deem a financial hardship in that the cost to eFile would significantly exceed the cost to file otherwise. Exactly how a financial hardship is determined is unclear at this point, but this is likely a 2016 consideration and those details will likely be better fleshed out then. In any event, we would encourage you to learn more about this waiver and share it with your clients. Of course, they should consult with their Tax Advisor on the appropriateness of Form 8508 for their organization. We just thought we would share this (potentially) good news as every bit of simplicity helps in this first year of ACA reporting!

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