IRS Provides Transition Relief for 2020 ACA Reporting

On Oct. 2, 2020, the Internal Revenue Service (IRS) issued Notice 2020-76 to:

• Extend the due date for furnishing forms under Sections 6055 and 6056 for 2020 from Feb. 1, 2021, to March 2, 2021; and
• Provide a final extension of good-faith transition relief from penalties related to 2020 information reporting under Sections 6055 and 6056; and
• Provide additional penalty relief related to furnishing 2020 forms to individuals under Section 6055. Under this relief, employers will only have to provide Form 1095-B to covered individuals upon request.

The due date for filing forms with the IRS for 2020 remains March 1, 2021 (since Feb. 28, 2021, is a Sunday), or March 31, 2021, if filing electronically.

Action Steps

The IRS is encouraging reporting entities to furnish 2020 statements as soon as they are able. No request or other documentation is required to take advantage of the extended deadline.

According to Notice 2020-76, this is the last year that the IRS intends to provide good-faith relief from penalties, since it was intended to be transitional relief only.

Highlights

• The deadline for furnishing individual statements under Sections 6055 and 6056 for 2020 has been extended for 30 days.
• Good-faith transition relief from penalties has also been extended for a final time for 2020 reporting.
• The due date for filing returns with the IRS for 2020 is not affected.

Important Dates

• March 2, 2021 – Deadline for furnishing 2020 Forms 1095-B and 1095-C to individuals
• March 1, 2021 – Deadline for 2020 filing with the IRS in paper form
• March 31, 2021 – Deadline for 2020 filing with the IRS electronically