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Issue Date: December 2017

We are entering another season of employer reporting deadlines, and the first round of letters from the IRS proposing employer shared responsibility payments under §4980H has been released. This reminds us that the employer mandate under §4980H of the ACA remains in effect and requires compliance to avoid potential penalties. All applicable large employers (ALEs) are subject to §4980H offer of coverage requirements and §6056 employer reporting requirements. ALEs who fail to comply with §4980H offer of coverage requirements and report accordingly to the IRS via Forms 1094-C and 1095-C may find themselves subject to penalties (employer shared responsibility payments).

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