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The IRS has released the draft instructions for Form 1094-C and Form 1095-C. There are no major changes from the 2016 reporting.

Multiemployer Plan Relief Extended

The draft instructions for Form 1095-C extend the existing multiemployer plan relief for 2017. This means that employers qualifying for the relief, for instance ALEs with union employees, who rely on the offer of coverage from the union to fulfill their requirement under the Employer Mandate, won't need to obtain eligibility and offer of coverage information for those employees. The instructions indicate this may change for 2018 and beyond.

Expired Transitional Relief

As anticipated, all mentions of transitional relief have been removed from both Form 1094-C and 1095-C.

Next Steps

The instructions continue to emphasize the importance of making sure employers are properly identifying their full-time employees using either the lookback or monthly measurement method appropriately to ensure accurate reporting. As the instructions and reports are finalized, Assurance will provide finalized updates and scenarios.

Information contained herein is not intended to constitute tax or legal advice and should not be used for purposes of evading or avoiding otherwise applicable regulatory responsibilities as issued by the federal or state government(s) and/or taxes owed under the Internal Revenue Code. You are encouraged to seek advice from your legal or tax advisor based on your circumstances.