On Friday, November 18th, the Department of the Treasury and Internal Revenue Service issued Notice 2016-70, which extends by 30 days the due date for furnishing the 2016 Forms 1095-B and 1095-C, from January 31, 2017, to March 2, 2017. This extension does not apply to the due date for filing the corresponding forms with the IRS by February 28, 2017 (if not filing electronically) or March 31, 2017 (if filing electronically).
Notice 2016-70 also extends the “good faith effort” transition relief provided to employers that can show that they have
made good faith efforts to comply with the information-reporting requirements under sections 6055 and 6056. The good faith effort standard will apply to both furnishing statements to individuals and for filing with the IRS for incorrect or incomplete information reported on the return or statement, such as missing and inaccurate taxpayer identification numbers and dates of birth, as well as other information required on the return or statement. In determining good faith, the IRS will take into account whether an employer or other coverage provider made reasonable efforts to prepare for reporting the required information to the IRS and furnishing it to individuals, such as gathering and transmitting the necessary data to an agent to prepare the data for submission to the IRS, or testing its ability to transmit information.
In addition, the IRS will take into account the extent to which the employer or other coverage provider is taking steps to
ensure that it will be able to comply with the reporting requirements for 2017 reporting (due in early 2018).
For additional information, questions or concerns, please feel free to contact David Mordo at firstname.lastname@example.org or