News & Analysis as of

Filing Deadlines Good Faith

Keating Muething & Klekamp PLL

Benefits Monthly Minute UPDATE: RxDC Reporting Relief

On December 23, 2022, FAQs were released outlining late-breaking RxDC Reporting Relief. Of note - 1. For the 2020 and 2021 data submissions that are due by December 27, 2022, the Departments will not take enforcement...more

Holland & Hart - The Benefits Dial

No More Mister Nice Guy…No More “Good-Faith” Relief for ACA Reporting Requirements

The good news is that the deadline to furnish individuals with the Form 1095-C or Form 1095-B reporting health care coverage in 2021 has been extended to March 2, 2022. The bad news is that the days of good-faith relief are...more

Verrill

Elimination of Good Faith Relief for ACA Reporting

Verrill on

On November 22, 2021, the Internal Revenue Service (IRS) published proposed regulations that codify, among other things, an automatic extension of the deadline for furnishing IRS Forms 1095-C to employees. IRS Forms 1095-C...more

McAfee & Taft

IRS announces relief for certain Form 1094/1095 reporting requirements

McAfee & Taft on

In a similar move as in previous years, the IRS has issued relief from certain Form 1094-C and 1095-C reporting requirements under the Affordable Care Act relating to employee health plans, as well as relief from certain...more

WilmerHale

Navigating the "Good Faith Effort" Standard for Reg BI and Form CRS Implementation

WilmerHale on

Firms must demonstrate a “good faith effort” to comply. Last month, SEC Chairman Clayton issued a public statement communicating that firms should not expect a delay of the June 30, 2020 compliance date for Regulation Best...more

Burr & Forman

Ho, Ho, Ho, ACA Reporting Relief Five Years in a Row

Burr & Forman on

Since 2015, employers and health insurers have been required to report health plan coverage information to the IRS and to individuals. Why? The information is necessary in order for the IRS to administer certain portions of...more

McDermott Will & Emery

Timely Actions – Highly Compensated Excise Tax Deadline Imminent

McDermott Will & Emery on

As an update on an important matter that we raised during McDermott’s May 8 Tax Symposium, it is critical to promptly assess whether to report any excise taxes imposed under Section 4960 as the deadline for filing Form 4720...more

Mintz - Intellectual Property Viewpoints

Double Check Your Filings, A Cautionary Tale at the PTAB

Recently in Nuna Baby Essentials, Inc. v. Britax Child Safety, Inc., IPR2018-01683, Paper No. 11 (PTAB Dec. 18, 2018), the Patent Trial and Appeal Board (“Board”) denied Petitioner’s motion to excuse the late filing of...more

Foley & Lardner LLP

Thank You IRS - Extensions for This Year’s ACA Tax Reporting

Foley & Lardner LLP on

The “Bottom Line” - Employers will have until March 2, 2018 to furnish Form 1095-C (“Employer-Provided Health Insurance Offer and Coverage”) to employees.,,...more

McDermott Will & Emery

CMS Aims to Stabilize Exchanges but Does Not Address Issuers’ Biggest Questions

McDermott Will & Emery on

CMS recently released a final rule with the goal of stabilizing Exchange markets for 2018. The agency also issued several significant guidance documents where CMS extended the deadlines for 2018 rate and Exchange qualified...more

Proskauer - Employee Benefits & Executive...

ACA Reporting Update – The Final Stretch

After months of preparation and multiple iterations of (sometimes conflicting) IRS guidance, health coverage providers and applicable large employers are nearing the end of the 2015 reporting season under the Affordable Care...more

Proskauer - Employee Benefits & Executive...

IRS Extends Deadlines for Affordable Care Act Reporting

On December 28, 2015, the IRS released Notice 2016-4, which extended the distribution and filing deadlines for the Affordable Care Act (ACA) reporting requirements set forth in Sections 6055 and 6056 of the Internal Revenue...more

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