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Extension for Good-Faith Reporting and 2016 Forms 1095-C and 1094-C

The Affordable Care Act (ACA) created information reporting requirements for certain large employers and issuers of health insurance coverage under Sections 6055 and 6056 of the Internal Revenue Code (Code). On November 18, 2016, the Internal Revenue Service issued Notice 2016-70, extending both the due date for furnishing individuals with Forms 1095-C and 1095-B, in addition to certain good-faith transition relief to the 2016 information reporting requirements under Code sections 6055 and 6056.

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How to Determine Full-Time Employment Status of Employees for the ACA Employer Shared Responsibility Mandate

As part of the insurance market reforms enacted under the ACA, large employers are required to maintain a certain level of health insurance for their common law employees (and only their common law employees) or pay a penalty — the so-called pay or play or employer shared responsibility rules.  The rules for determining which workers should, or even can, be offered coverage are quite daunting.  This article provides a road map for determining which workers must have an offer of health insurance coverage from the employer to avoid triggering penalties under the employer shared responsibility requirements.

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