Deadline Extended for 2019 Forms 1095-C

On December 2, 2019, the IRS issued Notice 2019-63, which provides:

• An extension of time, until March 2, 2020, for employers to provide Forms 1095-C to their full-time employees and other individuals; and

• An extension of relief from penalties for the 2019 reporting year for employers and other entities that make good-faith efforts to comply with the reporting requirements.

Notice 2019-63 does not, however, extend the deadline to provide completed Forms 1094-C and 1095-C (and Forms 1094-B and 1095-B) to the IRS (as described in Q/A-2 below). Nor does it provide any relief from providing Forms 1095-C to fulltime employees (“FTEs”). This means that all Applicable Large Employers (“ALEs”) must continue to provide Form 1095-C to any employee that was full time for any month of 2019.

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