On December 28, 2015, the IRS issued guidance extending the deadline for providing new Affordable Care Act tax forms to employees and to the IRS. This guidance provides a bit of breathing room to employers with 50. However, it does not remove the reporting obligations; large employers still need to focus quickly on these new rules.

Chart Comparing Deadlines. The old and new deadlines for the 1094 / 1095 forms are noted below.

Click here to view the image.

What if New Deadlines Cannot be Met? Even if an employer cannot meet the extended deadlines, the IRS still recommends that employers furnish and file the forms. The IRS notes that it will take the late furnishing and filing into consideration when determining whether to reduce penalties for reasonable cause. In addition, the IRS will take into consideration whether an employer made reasonable efforts to prepare for reporting.