While this new provision does not apply to 2015 Forms W2 filed in 2016, the IRS will start a regulatory process to allow truncated SSNs on Form W2. Regulations regarding allowing truncated TINs on Forms 1099-MISC may be updated, as well. The regulatory process is to examine issues that states might face regarding tax returns filed without full SSNs.
During the same informational teleconference, the IRS representative announced information related to the commuting benefit parity for 2015. A notice is to be released soon that will describe adjustment procedures employers may take if it is necessary to repay employees FICA and Medicare taxes on amounts that retroactively become nontaxable because of retroactive changes to the benefit limits.
ACA filing deadline extensions were clarified, particularly relating to the date for determining the late-filing penalty of $100 per form or $260 per form for 2015 ACA forms filed in 2016 90 days after August 1, causing the revised applicable date to be October 30.
- Employers have until March 31 to file Form 1095B and issue Forms 1095C to employees.
- Employers have until May 31 to file paper copies of ACA forms with the IRS.
- Employers have until June 30 to file electronic copies of the ACA forms with the IRS.
The IRS also announced concern over a decline in the amount of third-party sick pay reconciliation data. Forms 8922 Third Party Sick Pay Recap were first used in 2015, the first year that the IRS took over responsibility for collection of this data, previously collected by SSA on Forms W2. The concern is that because the IRS collected fewer of the Forms 8922 than the SSA collected Third Party Sick Pay W2s, there may be increased combined annual wage reconciliation issues resulting in substantial penalties and interest.