End of Good - Faith Reporting Relief & 1095 Distribution Timing Updates - From the Desk of Michelle Sheppard
(Posted on 02/03/22)
In prior years, the IRS has allowed for penalty relief for entities who have reported incorrect or incomplete information when good-faith efforts were made to comply with reporting requirements under Section 6055 and 6056 for the 1094/1095 reporting. Some examples of what this relief applied to were missing and inaccurate tax identification numbers and dates of birth. When determining good-faith, the IRS would take into account whether reasonable efforts were made to prepare for submission to the IRS and furnishing to employees and covered individuals prior to the due dates. The intention was always for this relief to be transitional. With this, it has been proposed that the 2020 tax year is the last year that the good-faith relief will be applied and for filings of the 2021 tax year, this will no longer apply.

Additionally, a 30 day extension has yet again been made for furnishing the 1095-B and 1095-C forms to employees from January 31st, 2022 to March 2nd 2022. This is an extension that has been made each year since 2015. A proposed rule has been made by the IRS that would extend that deadline permanently beginning with the 2021 year.

Additional details and links to the IRS bulletins can be found below.