As we discussed in our blog dated December 26, 2017, the IRS Notice 2018-06 extended the due date for large employers to furnish employees with statements regarding minimum essential coverage provided by the employer.
This notice also extended transition relief to employers that can show that they have made good-faith efforts to comply with the information-reporting requirements under sections 6055 and 6056 for 2017 (both for furnishing to individuals and for filing with the Service) for incorrect or incomplete information reported on the return or statement. This relief originally was granted for 2015 information-reporting requirements and then extended for 2016. Notice 2018-06 extends the relief to 2017 requirements. As a reminder, this relief applies to missing and inaccurate taxpayer identification numbers and dates of birth, as well as other information required on the return or statement. In determining good faith, the Service will take into account whether an employer or other coverage provider made reasonable efforts to prepare for reporting the required information to the Service and furnishing it to employees and covered individuals, such as gathering and transmitting the necessary data to an agent to prepare the data for submission to the Service or testing its ability to transmit information to the Service. In addition, the Service will take into account the extent to which the employer or other coverage provider is taking steps to ensure that it will be able to comply with the reporting requirements for 2018.