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2015 ESRP Responses in Review

With the 2016 employer mandate tax assessment letters hitting employer desks this week, it seems like a good time to summarize our experience with the 2015 ESRP process. ...more

IRS Form 14764: Response to Proposed Assessment of 2015 Employer Mandate Tax

On November 17, the IRS published the Form that Applicable Large Employers must use to respond to IRS letters regarding proposed assessment of 2015 employer mandate taxes. Form 14764 is a paper, mail-in “ESRP Response” that...more

At Last, Our Employer Mandate Tax Assessment Guidance Has Come Along

Just days ago, “Questions and Answers on Employer Shared Responsibility Provisions Under the Affordable Care Act,” No. 57 read as follows: Does the IRS expect to publish more information about the employer shared...more

“Hello? Chicken Little Here. Sky’s falling.”

We don’t blame you for hearing that whenever someone warns of employer mandate taxes coming your way.  Nevertheless, we’re donning the chicken suit once again to keep you aware.  This time, we’ll keep it short and mainly...more

ACA Compliance Validation (ACV) System: Ready for Prime Time?

ACA “repeal” proposals at this point seem like zombie extras – walking dead, and none of them purports to repeal employer mandate taxes that accrued in 2015. Collection is coming; only the timing is in question. ACV 2.0 is...more

Updated Employer Mandate Tax Assessment Guidance: “Would You Believe …?”

Maxwell Smart, aka “Agent 86” in the 1960’s TV series Get Smart, claimed to have survived “fiendish” water torture – 300 gallons at the rate of one drop a minute. When disbelieved, he asked, “Would you believe a quart?” The...more

The Surprise of Familiarity

Watching from afar the Scouts attempting to earn their orienteering merit badges, we could see it on the boys’ faces. They were lost; they were scared. They should have reached their destination an hour ago. Soon, these...more

2015 Form 1095-C Penalty Letters: Have You Got Mail?

Since late December, 2016, many Applicable Large Employer Members have received IRS Letter 5699 from a Tax Compliance Officer at an address in Florence, Kentucky. The “Dear Taxpayer” letter is headed: “Request for Employer...more

Hitch In the Giddy-up: Round-up of Developments January 19 – 27

As previously reported, § 2001 of the 2017 budget bill required all ACA repeal/replace bills to be filed and reported from assigned committees by Friday, January 27, 2017. That didn’t happen. Since our last posting, the...more

Draft IRS Publication 5164 (Early Look) for Processing Year 2017

If your EIN will have 250 or more full-time employees in 2016 (counting each person who was full-time in any month) you’ll need next year to file your 2016 ACA Information Returns – Forms 1094-B and 1095-B or Forms 1094-C and...more

2016 Draft Forms 1094-C and 1095-C and Instructions: What’s New, Page-by-Page

In the ACA realm, change is the only constant, so don’t take this to the bank. We’re telling you what we see for the first time, on a first reading of the draft 2016 Forms and Instructions that the IRS has released since...more

2015 ACA Information Reporting: Parts Sold Separately, Some Assembly Required

Ten days before the deadline for electronic filing of 2015 Forms 1094-C and 1095-C, many employers are discovering that they contracted for less than all the needed services. Here’s what we’re seeing all too...more

So I Made This Little 1095-C Mistake. Big Deal?

The 2015 Instructions for Forms 1094-C and 1095-C tell Applicable Large Employers how to furnish and file corrections to incorrectly filed Forms 1095-C. ...more

Heffalumps, Woozles and Limited Non-Assessment Periods: Very Confusel

So, you were a 2015 Applicable Large Employer. You waited too late to outsource your generation, furnishing and filing of 2015 Forms 1095-C. Fortunately, you believe, you are permitted to file on paper, by May 31, 2016,...more

ACA Information Return Deadlines Extended

On December 28, 2105, the IRS released its Notice 2016-4, granting much needed time for employers and their filing services to catch up to Affordable Care Act Information Return (AIR) Program developments. ...more

Give Me Just A Little More Time . . .

Was the title of a 1970 soul hit for the Chairmen of the Board. Though your love for ACA information reporting is unlikely to grow as a result, you may need a little more time to get it done. This article responds to multiple...more

Request for Information about ALE Reporting Status

We work closely with employers (mostly ALEs) and an array of service providers – payroll processors, benefit plan consultants and administrators, software developers and transmitters, employee leasing firms, insurance brokers...more

Do Seasonal Workers “Count” for Forms 1094-C and 1095-C?

We were asked that recently, proving that there is such a thing as a wrong question. Let’s break it down. The same person may be both a “seasonal worker” and a “seasonal employee,” but those terms are used to discuss separate...more

2015 Form 1095-C Reporting: IT Vendor Survey

On August 18, 2014, we posted our, “First Look at ACA Employer Compliance Software.” It’s time for an update. We invited less than a dozen vendors to answer these twenty-two questions....more

Draft 2015 Forms and Instructions for ACA Coverage Offer Information Reporting: Forms 1094-B, 1095-B, 1094-C, 1095-C and 8809

At about the same time as last year, the IRS has released draft ACA coverage information reporting Forms and Instructions to be used early next year. There are many small differences and one HUGE difference. The IRS decided...more

Simple ACA Rules for Simple (But Not Small) Employers

If you had at least 50 but less than 100 full-time employees (on an aggregated basis, including full-time equivalents) in an average month in 2014, then you are an ACA “Applicable Large Employer” with ALE reporting...more

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