Following the July 31, 2017, deadline for renewing an FFI agreement, the IRS announced in a new FAQ that a participating FFI (including a reporting model 2 FFI) that renews its FFI agreement by October 24, 2017, will continue to be treated as a participating FFI. Rev. Proc. 2017-16, which includes the current FFI agreement, … Continue Reading
Facing likely defeat, Republicans have pulled the American Health Care Act, which would have made numerous changes to the information reporting provisions and employment tax provisions of the Affordable Care Act (ACA). The legislation would have also created a new information reporting requirement by adding Section 6050X to the Code. The House was scheduled … Continue Reading
The IRS today released Notice 2017-09 providing guidance on the de minimis safe harbor for errors in amounts reported on information returns. The safe harbor was added to Sections 6721 and 6722 by the Protecting Americans from Tax Hikes Act of 2015 (PATH Act). Under the statute, filers are not subject to penalties under either … Continue Reading
Earlier this month, the IRS announced in interim guidance that it would amend Section 20.1.7 of the Internal Revenue Manual to provide a methodology for the calculation of intentional disregard penalties under Section 6721 for filers who fail to file information returns electronically when required. In general, filers of more than 250 information returns are … Continue Reading
On July 29, the IRS issued proposed regulations under Section 6055 that seek to clarify a number of issues raised by commenters in response to the original proposed regulations under Section 6055 and Notice 2015-68. Filers may rely on the proposed regulations for calendar years ending after December 31, 2013, making them applicable at the option of … Continue Reading
In its Affordable Care Act (ACA) Information Returns (AIR) Working Group Meeting on June 14, the IRS discussed several outstanding issues related to ACA reporting under Sections 6055 and 6056 of the Internal Revenue Code. Section 6055 generally requires providers of minimum essential coverage to report health coverage. Section 6056 generally requires applicable large employers … Continue Reading
The IRS released a modified private letter ruling superseding a ruling issued in late 2015 under Section 6050W. That ruling had determined that the party requesting the ruling was a third-party settlement organization. The new ruling does not change the conclusion, but removes one rationale upon which the earlier ruling had based its determination. In … Continue Reading
