The IRS has extended the deadline for employers to provide participants in their group medical plans with their 2020 individual participant information statements.
Under the Affordable Care Act (ACA), employers that are “applicable large employers” (generally, those with 50 or more full-time employees/full-time equivalent employees in the previous year) that maintain a group medical plan, as well as employers of any size that maintain a self-insured group medical plan, are required to file information returns with the IRS and to provide related individual information statements to plan participants.
Under existing regulations, for each calendar year, the deadline for the participant statements is the following Jan. 31, and the deadline for the IRS filing is the following Feb. 28 (March 31 if filed electronically). The regulations also provide for an available automatic 30-day extension for the IRS filing deadline (by filing Form 8809, “Application for extension of time to file information returns”), as well as a conditional 30-day extension available for both deadlines upon a showing of good cause.
In recently issued Notice 2020-76, the IRS announced that for purposes of the 2020 ACA employer reporting requirements:
- The Jan. 31, 2021, participant information statement deadline is extended to March 2, 2021, and there will be no additional extensions available.
- The Feb. 28/March 31, 2021, IRS information return deadline is not extended; however, the automatic and conditional 30-day extensions will continue to be available.
Any advice contained in this communication, including attachments and enclosures, is not intended as a thorough, in-depth analysis of specific issues. Nor is it sufficient to avoid tax-related penalties. This has been prepared for information purposes and general guidance only and does not constitute professional advice. You should not act upon the information contained in this publication without obtaining specific professional advice specific to, among other things, your individual facts, circumstances and jurisdiction. No representation or warranty (express or implied) is made as to the accuracy or completeness of the information contained in this publication, and CohnReznick LLP, its partners, employees and agents accept no liability, and disclaim all responsibility, for the consequences of you or anyone else acting, or refraining to act, in reliance on the information contained in this publication or for any decision based on it.
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