The IRS has clarified the proper method for completing IRS Form 1094-C
on behalf of a controlled group. IRS Form 1094-C is the transmittal form for IRS Forms 1095-C
. Applicable Large Employers subject to The Affordable Care Act’s reporting requirements are required to submit their IRS Form 1094-Cs and 1095-Cs to the IRS by May 31, 2016 if filing on paper, and by June 30, 2016 if filing electronically. Employers filing 250 or more 1095-Cs are required to report electronically.
The IRS stated that each member of an Aggregated Applicable Large Employer (e.g. a controlled group with 50 or more full-time employees including full-time equivalents) must complete its own Authoritative Transmittal 1094-C. Authoritative Transmittal filers complete Parts I, II, III, and IV of IRS Form 1094-C.
Company A, Company B, and Company C all share common ownership to a level sufficient for establishing a controlled group. The three companies combined employ 55 full-time employees including full-time equivalents. As a result:
- Each separate employer (Company A, Company B, and Company C) is an Aggregated Applicable Large Employer subject to Pay-or-Play (Employer Shared Responsibility Provisions of The Affordable Care Act)
- Each separate employer (Company A, Company B, and Company C) is also subject to the associated reporting requirements and must file its own 1094-C Authoritative Transmittal, using its own EIN.
Other helpful resources:
To review a recorded presentation addressing Aggregated Applicable Large Employers and the 1094-C reporting requirement, please click here