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Treasury Delays Employer Responsibility and Information Reporting Requirements Until 2015

The Treasury made an announcement in the “Treasury Notes” blog that it is delaying the implementation of the Code section 6055 and 6056 information reporting provisions until 2015.

This news was expected since no reporting guidance has been issued to date. Surprisingly, however, Treasury also announced its decision to delay the effective date for the employer shared responsibility liability itself until 2015.

The announcement states that Treasury recognizes that the Code section 4980H employer shared responsibility provisions could not be enforced without information reporting, and so Treasury is also delaying the application of the Code section 4980H employer shared responsibility provisions until 2015.

This is welcome news given the fact that the employer shared responsibility proposed regulations, which were published on January 2, 2013, leave several questions unanswered (see http://www.groom.com/resources-734.html). Formal guidance setting forth the details of this transition relief is expected shortly.

From Treasury Notes blog:  http://www.treasury.gov/connect/blog/Pages/Continuing-to-Implement-the-ACA-in-a-Careful-Thoughtful-Manner-.aspx