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Proposed IRS Regulations Extend Electronic Filing Requirement to More Employers

New proposed regulations would extend the electronic filing requirement under IRS Reg. §301.6011-2 to more employers who may not have been required to file electronically.

Currently, the IRS regulations require that any employer that is filing 250 or more information returns during the calendar year must file those returns electronically.

Historically, under the non-aggregation rules, the determination of whether an employer met the 250-threshold was applied separately to each type of information and corrected information return the employer filed. Under the new proposed regulations, the non-aggregation rule would no longer apply.

For employers, this means that the employer must count all information returns of any type filed with the IRS when determining whether they file 250 or more information returns. Additionally, any employer that is required to file electronically must also file any corrections electronically under the new proposed regulations. Notably, however, any employer that is required to file electronically will still have the opportunity to request a waiver from the electronic filing requirement.

The new regulations are effective for filings after January 1, 2019, or, if later, once the proposed regulations are finalized.

The electronic filing requirement may apply to all information returns, including but not limited to:

  • 1094-C, Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns
  • 1095-C, Health Insurance Offer and Coverage Insurance
  • 1094-B, Transmittal of Health Coverage Information Returns
  • 1095-B, Health Coverage
  • 5498-SA, HSA, Archer MSA, or Medicare Advantage MSA Information
  • 1099-SA, Distributions from an HSA, Archer MSA, or Medicare Advantage MSA
  • 1099-LTC, Long-Term Care and Accelerated Death Benefits
  • 1099-H, Health Coverage Tax Credit (HCTC) Advance Payments
  • 1099-DIV, Dividends and Distributions
  • 1099-INT, Interest Income
  • 1099-MISC, Miscellaneous Income
  • 1099-S, Proceeds from Real Estate Transactions
  • 1098-E, Student Loan Interest Statement
  • 1098-T, Tuition Statement
  • 1099-Q, Payments from Qualified Education Programs (Under Sections 529 and 530)
  • 5498-ESA, Coverdell ESA Contribution Information
  • 3921, Exercise of an Incentive Stock Option Under Section 422(b)
  • 3922, Transfer of Stock Acquired Through an Employee Stock Purchase Plan Under Section 423 (C)
  • 1099-R, Distributions from Pensions, Annuities, Retirement or Profit-Sharing Plans, IRAs, Insurance Contracts, etc.
  • 5498, IRA Contribution Information

To learn more about the proposed IRS regulations regarding electronic filing requirements, reach out to your OneDigital consultant.


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  1. Hi:
    I am a One Digital partner and wanted to make sure these filings are for employers that are self-funded, correct? If fully insured, they don't have to do this.
    Also, the group size is for 250 or more or is it for 100 or more?
    Please clarify, if you would.
    Thanks, Cheryl

    1. @CherylBranch The electronic filing requirements referenced in this article are not specific to health plan filings. This is the electronic filing requirement for various IRS filings an employer may be required to complete, including non-health tax forms. Accordingly, the 250 threshold for electronic filing applies regardless of whether the health plan is fully insured or self-insured.

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