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Final 2015 ACA Reporting Forms Released

September 18, 2015


Final 2015 ACA Reporting Forms Released

September 18, 2015

Authored by: Chris Rylands

For those still trying to sort out the ACA reporting rules, the IRS has released the final forms and instructions for 2015 on its website.  They can found at the links below:

Employer Reporting

IRS Form 1095-C

IRS Form 1094-C

IRS Instructions to 1094-C & 1095-C

Coverage Provider Reporting

IRS Form 1095-B

IRS Form 1094-B

IRS Instructions to 1094-B & 1095-B


In addition, the IRS recently released a notice announcing upcoming proposed changes to the reporting rules, available here.

We’ll provide more analysis in the coming days, but wanted to send these out now for those who were anxiously awaiting their arrival.

The Tax Man Commeth Not to Data Breach Victims

The Tax Man Commeth Not to Data Breach Victims

September 3, 2015

Authored by: Denise Erwin and Chris Rylands

ID TheftThe IRS has issued some favorable guidance on the tax treatment of identity protection services provided to data breach victims.  In Announcement 2015-22, the IRS indicated that when an organization experiences a data breach, and it provides identity protection services to individuals whose information may have been compromised, the IRS will not assert that the individual must include the value of the services in gross income.  In addition, the IRS says that when an employer provides such services as a result of a data breach involving the recordkeeping systems of the employer, or the employer’s agent or service provider, the employer will not be required to include the value of the services in the employee’s gross income and wages.  The Announcement also indicates that the IRS will not assert that these amounts need to be reported on an information return (such W-2 or 1099-Misc.).

According to the Announcement, the “identity protection services” to which this guidance applies include credit reporting and monitoring services, identity theft insurance policies, identity restoration services and other similar services, but only when provided in connection with a data breach that occurs as a result of “hacking” or otherwise.  The tax relief provided by this guidance does not apply where an employer provides these services to its employees as part of its regular compensation and benefits package.  Nor does it apply to cash received in lieu of identity

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