Eight Facts for ALEs about New Information Statements to be Filed in 2016 (12/29/15)

The Affordable Care Act requires applicable large employers to file:

  • Form 1094-C, Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns
  • Form 1095-C, Employer-Provided Health Insurance Offer and Coverage

Here are eight basic facts for employers:

  • The due date for furnishing these forms is extended.
    • The due date for furnishing the 2015 Form 1095-B and the 2015 Form 1095-C to the insured and employees is extended from January 31, 2016, to March 31, 2016.
    • The due date for health coverage providers and employers furnishing the 2015 Form 1094-B and the 2015 Form 1094-C to the IRS is extended from February 28, 2016, to May 31, 2016 if not filing electronically.
    • The due date for health coverage providers and employers electronically filing the 2015 Form 1094-B and the 2015 Form 1094-C with the IRS is extended from March 31, 2016, to June 30, 2016.
  • While the IRS is prepared to accept information reporting returns beginning in January 2016 and employers and other coverage providers are encouraged to furnish statements and file the information returns as soon as they are ready.
  • An ALE is required to file Form 1094-C with the IRS; however, an ALE is not required to furnish a copy of Form 1094-C to its full-time employees.
  • Generally, an ALE must file Form 1095-C or a substitute form for each employee who was a full-time employee for any month of the calendar year.
  • In addition, an ALE that sponsors a self-insured plan must file Form 1095-C for each employee who enrolls in the self-insured health coverage or enrolls a family member in the coverage, regardless of whether the employee is a full-time employee for any month of the calendar year.
  • Form 1095-C is not required for the following employees, unless the employee or the employee’s family member was enrolled in a self-insured plan sponsored by an ALE member:
    • An employee who was not a full-time employee in any month of the year.
    • An employee who was in a limited non-assessment period for all 12 months of the year.
  • If an ALE member sponsors a health plan that includes self-insured options and insured options, the ALE member should complete Part III of Form 1095-C only for employees and family members who enroll a self-insured option.
  • An ALE member that offers coverage through an employer-sponsored insured health plan and does not sponsor a self-insured health plan should NOT complete Part III.
  • An ALE may provide a substitute Form 1095-C; however, the substitute form must include the information on Form 1095-C and must comply with generally applicable requirements for substitute forms.

For more information, see the Instructions for Forms 1094-C and 1095-C.

No Author Biography has been linked to this Article.

Related Articles

stevenson
May 8, 2022
My life in 1982 was in a bit of turmoil. I had recently gotten married and was working as in-house counsel for a regional furniture retailer. My position included a lot of collection work – beating up on debtors in state and bankruptcy courts. I was not unhappy but I was not comfortable with my work – it was clear...
February 10, 2019
By Leo G. Spanos, Senior Staff Attorney to Martha G. Bronitsky, Chapter 13 Trustee, Northern District of California (Oakland Division) Courts around the country are split on whether property acquired post-chapter 13 confirmation remains property of the estate or vests in the debtor for all purposes absent contrary language in the plan or confirmation order under 11 U.S.C. § 1327(b).1...
Members
Copy of Hildebrand-2016
February 26, 2023
In examining the effect of vesting of property of the estate at confirmation of a Chapter 13 plan, bankruptcy court examines the impact of five different theories on how post-confirmation property is to be treated, settling on the “Estate Replenishment Theory,” but does not decide if the debtors can receive the proceeds. (Fenimore) In re Marsh, 2023 WL 215263 (Bankr....
Members
ahern_larry_regular
May 15, 2022
Background - In re Taggart In 2019, the Supreme Court rendered its opinion in In re Taggart,1 which was the subject of earlier analyses: (1) Is a Finding of Contempt Precluded by a "Good Faith" but Unreasonable Belief that an Action Does Not Violate the Discharge Injunction?; (2) Looking Beyond . . . It looks like you are not signed...
Members
Karen Jolley, headshot
February 11, 2024
“Several recent bankruptcy cases have considered the circumstances under which funds held in, derived from, or contributed to a retirement account may be exempt from the bankruptcy estate.”
Members
September 27, 2020
By The Honorable William Houston Brown (Retired) Disgorgement of fees for nondisclosure. The Tenth Circuit held that the “default sanction” for an attorney’s failure to satisfy disclosure obligation is full disgorgement of fees paid. While full disgorgement may not be required in particular circumstances, the “default sanction” principle required reversal and remand. The bankruptcy court, affirmed by the BAP, had...
Members
January 31, 2021
By Rachel Jones, Staff Attorney to Chapter 13 Standing Trustee Chris Micale, Western District of Virginia (Roanoke) The events of 2020 have had a devastating impact on the very low-income population. The working poor are struggling, particularly those working in sectors such as hospitality and tourism. State and Federal funding and local programs such as food banks and community action...
September 27, 2020
By The Honorable William Houston Brown (Retired) Debtors’ attorney fees not authorized under Equal Access to Justice Act (EAJA). Although the Chapter 13 debtors had prevailed before the Ninth Circuit, In re Sisk, 962 F.3d 1133 (9th Cir. 2020), their application for attorney fees as prevailing parties under EAJA was denied. That Act did not authorize awards of attorney fees...
Members
February 21, 2021
By William J. Purdy III (Soquel, CA) Got an EDD tax form 1099 but no benefits? At this moment, POTENTIALLY hundreds of thousands of California taxpayers are enjoying the ghastly experience of receiving a Form 1099G courtesy of the California EDD for unemployment benefits the taxpayer never received. The problem is not confined to California; it’s so prevalent, the IRS...
Members
September 8, 2019
By Cathy Moran, Esq. (Redwood City, CA) The Federal Reserve reported that 40% of Americans couldn’t meet a $400 emergency without borrowing. A significant slice of them couldn’t pay it at all. So, a Bloomberg economist devoted his column to deconstructing how the press and political figures, in his opinion, misused that finding. OMGoodness. The guy was too caught up...

Looking to Become a Member?

ConsiderChapter13.org offers a forum to advance continuing education of consumer bankruptcy via access to insightful articles, informative webinars, and the latest industry news. Join now to benefit from expert resources and stay informed.

Webinars

These informative sessions are led by industry experts and cover a range of consumer bankruptcy topics.

Member Articles

Written by industry experts, these articles provide in-depth analysis and practical guidance on consumer bankruptcy topics.

Industry News

The Academy is the go-to source for the latest news and analysis in the Chapter 13 bankruptcy industry.

To get started, please let us know which of these best fits your current position: