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TOP 15 TAX DEVELOPMENTS OF 2015

(Parker Tax Publishing January 6, 2016)

Last year saw some major developments on the federal tax front, many of them quite positive. In particular, 2015 ended on a high note with the permanent extension of increased Section 179 expensing limits and several other perennial “extender” tax breaks, along with the temporary extensions of many more.

Earlier in the year, practitioners were happy to see the IRS waive the requirements to file Form 3115 for many small businesses adopting the new tangible property regulations, although many were furious that the IRS had not done so sooner. And the entire nation was treated to yet another tax-centric battle over the existence of Obamacare last summer when the Supreme Court upheld the sweeping healthcare law for a second time.

A recap of these key developments and a dozen others follows.

IRS Ends Confusion Over Form 3115 Requirements for Repair Regs.

As tax professionals focused on the implementation of the IRS’s new tangible property regulations (“repair regs”) in early 2015, many became concerned that nearly every business with depreciable property would have to file a Form 3115, Application for Change in Accounting Method, to adopt any applicable method of accounting changed by the regulations. Some practitioners found this prospect daunting, as Form 3115 is notoriously difficult and time-consuming.

Relief came in February via Rev. Proc. 2015-20. The revenue procedure waived the requirement for small businesses to file Form 3115, providing instead a simplified procedure for changing accounting methods under the repair regs.

Eligible taxpayers were permitted to apply the new regs on a prospective basis to tax years beginning in 2014. Applying the rules prospectively eliminated the requirement to file Form 3115, as well as the need to make a Code Sec. 481(a) adjustment related to prior tax years.

For a full discussion of relief provided by Rev. Proc. 2015-20, see Parker's in-depth article:
IRS Ends Confusion Over Form 3115 Requirements.

 

Year-end Legislation Extends Popular Business and Individual Tax Breaks

In mid-December, the President signed into law the Protecting Americans from Tax Hikes Act of 2015 (PATH) (Pub. L. 114-74). PATH permanently extends many tax breaks and temporarily extends dozens of others for periods ranging from two to five years.

For businesses, the main highlight of the new law is the permanent extension of the Code Sec. 179 election. Under PATH, the Code Sec. 179 expensing limitation and phase-out amounts have been permanently increased to the amounts available in years 2010 through 2014: $500,000 and $2 million, respectively. Both the $500,000 and $2 million limits are indexed for inflation beginning in 2016. In addition, the law modifies the expensing limitation by treating air conditioning and heating units placed in service in tax years beginning after 2015 as eligible for expensing. The provision further modifies the expensing limitation with respect to qualified real property by eliminating the $250,000 cap beginning in 2016. The special rules that allow expensing for computer software and qualified real property (qualified leasehold improvement property, qualified restaurant property, and qualified retail improvement property) also are permanently extended.

PATH also permanently extended the ever popular research and development (R&D) tax credit. Additionally, beginning in 2016, businesses with $50 million or less in gross receipts may claim the R&D credit against alternative minimum tax (AMT) liability. Also beginning in 2016, qualified small businesses ($5 million or less in gross receipts and no gross receipts for any tax year preceding the five-tax-year period ending with such tax year) may claim the R&D credit against their payroll tax liability.

Another big highlight for businesses under the new law is the temporary extension of the bonus depreciation rules. Bonus depreciation is available for property acquired and placed in service during 2015 through 2019 (with an additional year for certain property with a longer production period). The bonus depreciation percentage is 50 percent for property placed in service during 2015, 2016, and 2017, and phases down with 40 percent in 2018, and 30 percent in 2019.

One of the biggest wins for lower income individuals is the permanent extension of the enhanced child tax credit (CTC). The CTC is a $1,000 credit. To the extent the CTC exceeds the taxpayer's tax liability, the taxpayer is eligible for a refundable credit (the additional child tax credit) equal to 15 percent of earned income in excess of a threshold dollar amount (the "earned income" formula). Until 2009, the threshold dollar amount was $10,000 indexed for inflation from 2001 (which would be roughly $14,000 in 2015). Since 2009, however, this threshold amount has been set at an unindexed $3,000 and was scheduled to expire at the end of 2017, returning to the $10,000 (indexed for inflation) amount. The law permanently sets the threshold amount at an unindexed $3,000.

PATH also made favorable changes to the earned income tax credit (EITC) that had previously been temporary. For 2009 through 2017, the EITC amount had been temporarily increased for those with three (or more) children and the EITC marriage penalty had been reduced by increasing the income phase-out range by $5,000 (indexed for inflation) for married couples filing jointly. The law makes these provisions permanent.

For a full discussion of the Protecting Americans from Tax Hike Act of 2015, see
Congress Permanently Extends Numerous Tax Provisions.

 

New Tax Return Due Dates and Extension Deadlines Take Effect Beginning for 2016 Tax Years

In July, as part of the Surface Transportation and Veterans Health Care Choice Improvement Act of 2015, Congress made significant changes to the due dates of C corporation and partnership tax returns. The changes are generally effective for tax years beginning after 2015. Along with those changes came modifications to the extension deadlines for numerous entity returns.

For tax years beginning after 2015, partnerships will be required to file their returns by the 15th day of the third month following the close of a tax year. For calendar year partnerships, the due date will be March 15, instead of April 15.

OBSERVATION: The filing deadlines for S corporation returns remain unchanged, meaning that partnership and S corporation returns will now share the same due dates.

In general, for tax years beginning after 2015, C corporations will have until the 15th day of the fourth month following the close of the tax year to file their returns. For calendar year C corporations, this means the due date will be April 15, instead of March 15.

A special rule exempts C corporations with fiscal years ending on June 30 from this change until tax years beginning after Dec. 31, 2025. Thus, the filing deadline for such corporations will remain September 15 until 2026 (when it will change to October 15).

The legislation also changed many of the automatic extension periods. For calendar year C corporations, the new rules provide a five-month automatic extension for returns for tax years beginning after December 31, 2015, and ending before January 1, 2026. The extension period is a month shorter, but results in the same September 15 extended deadline because of the new due date for C corporation returns (i.e., April 15).

For fiscal year C corps with tax years ending on dates other than June 30, the length of automatic extensions remains unchanged at six months. For fiscal year C corps with tax years ending on June 30, a special seven month automatic extension applies for tax years beginning after December 31, 2015 and ending before January 1, 2026.

For tax years ending after December 31, 2025, automatic extensions for all C corporations will be six months. The new law also requires the IRS to appropriately modify regulations to provide maximum extensions for certain other returns of calendar year taxpayers for tax years beginning after December 31, 2015, including: a six month extension ending on September 15 for partnerships filing Form 1065; a 5-1/2 month extension ending on September 30 for trusts filing Form 1041; a 3-1/2 month extension ending on November 15 for employee benefit plans filing Form 5500; and a six month extension ending on November 15 for exempt organizations filing Form 990.

For a full discussion of the changes in tax return due dates, see
Congress Swaps Partnership and C Corp Deadlines, Overturns Supreme Court Decision.

 

Bipartisan Budget Act Substantially Changes Partnership Audit Rules

The Bipartisan Budget Act of 2015 (Pub. L. 114-74) repealed the voluntary centralized audit procedures for electing large partnerships (ELPs), as well as the TEFRA procedures (i.e., rules adopted as part of the Tax Equity and Fiscal Responsibility Act of 1982) for auditing most other partnerships. Those rules have been replaced with a new system in which audits and adjustments of all partnership items are generally determined at the partnership level, although an opt-out provision to the new rules is available for certain partnerships. Under the new rules, distinctions among partnership items, non-partnership items, and affected items no longer exist.

The changes relating to the partnership audit provisions generally apply to returns filed for partnership tax years beginning after December 31, 2017. However, a partnership may elect to apply the new partnership audit rules to any return of the partnership filed for partnership tax years beginning after November 2, 2015, and before January 1, 2018.

Practice Tip: In deciding whether to adopt the new rules early, practitioners should consider that TEFRA is a tough audit process for the IRS. For partnerships that have 100 or fewer partners, the IRS is required to notify each partner at the beginning and at the end of the partnership audit and recalculate each partner's liability. Additionally, the IRS has run into significant statutes of limitation issues as a result of failing to properly identify a TEFRA partnership. Thus, there are generally less partnership audits. Congress saw getting rid of TEFRA as a revenue raiser because they believe that, without TEFRA, there will be more partnership audits and, thus, more money flowing into the Treasury. By making an early election into the non-TEFRA rules, a partnership may be increasing its chances of being audited.

For a full discussion of the partnership audit changes in the Bipartisan Budget Act of 2015, see
Bipartisan Budget Act Avoids Government Shutdown, Replaces TEFRA Partnership Audit Procedures.

 

Tax Preparer Due Diligence Requirements Extended to Child Tax Credit and American Opportunity Tax Credit

Under Code Sec. 6695(g), a penalty of $500 may be imposed on a tax return preparer who prepares a tax return or refund request claiming the earned income tax credit (EITC), unless the tax return preparer exercises due diligence with respect to that claim. The due diligence requirements extend to both the determination of eligibility for the credit and the amount of the credit. Reg. Sec. 1.6695-2 details how to document compliance with those due diligence requirements. The position taken with respect to the EITC must be based on current and reasonable information that the paid preparer develops, either directly from the taxpayer or by other reasonable means. The preparer may not ignore implications of information provided by a taxpayer, and is expected to make reasonable inquiries about incorrect, inconsistent, or incomplete information. The conclusions about eligibility and computation, as well as the steps taken to develop those conclusions, must be documented using Form 8867, Paid Preparer’s Earned Income Credit Checklist, which is filed with the return.

Effective for tax years beginning after December 31, 2015, The Protecting Americans from Tax Hike Act of 2015 requires tax return preparers to meet due diligence requirements similar to those applicable to returns claiming an EITC if they prepare federal income tax returns on which a child (or additional child) tax credit is claimed or on which the American opportunity tax credit is claimed.

For a full discussion of changes made by The Protecting Americans from Tax Hike Act of 2015, see
Congress Permanently Extends Numerous Tax Provisions Including Increased Section 179 Expensing and Enhanced Child Tax Credit.

 

Ninth Circuit Overturns Tax Court: Unmarried Co-owners Apply Mortgage Interest Limitation on Per-Taxpayer Basis

Under Code Sec. 163(h)(3), a taxpayer can deduct the interest paid on home acquisition indebtedness and/or a home equity line of credit for a principal residence and a second home. Specifically, the statute provides that the aggregate amount that a taxpayer may treat as acquisition debt for any year cannot exceed $1,000,000 ($500,000 in the case of a married individual filing a separate return). The aggregate amount that a taxpayer may treat as home equity debt for any year cannot exceed $100,000 ($50,000 in the case of a separate return by a married individual). Although the statute is specific with respect to a married taxpayer filing a separate return, it does not specify whether, in the case of co-owners who are not married, the debt limits apply on a per-residence or per-taxpayer basis.

In 2012, the Tax Court was asked to decide whether the statutory limitations that apply to deductible interest on acquisition and home equity indebtedness are applied on a per-residence or per-taxpayer basis where residence co-owners are not married to each other. As the number of heterosexual and same-sex couples living together has skyrocketed, the decision had major implications for thousands of taxpayers. Unfortunately for taxpayers, in Sophy v. Comm'r, 138 T.C. 204 (2012), the Tax Court sided with the IRS and concluded that the limitations of Code Sec. 163(h) apply to the aggregate indebtedness on up to two residences, and co-owners who are not married to each other may not deduct more than a proportionate share of interest on $1.1 million.

In August, however, in Voss v. Comm'r, 2015 PTC 275 (9th Cir. 2015), the Ninth Circuit reversed the Tax Court’s decision in Sophy and held that, when unmarried taxpayers co-own a qualifying residence, the limitation on the qualified residence interest deduction applies on a per-taxpayer, rather than on a per-residence, basis.

OBSERVATION: The decision means that unmarried taxpayers who co-own their home are not limited to deducting the same amount as married taxpayers filing jointly. Instead, they can deduct up to twice the amount of interest as married taxpayers.

For a full discussion of the Tax Court’s decision in Voss, see
Ninth Circuit Reverses Tax Court: Unmarried Co-owners Apply Mortgage Interest Limitation on Per-Taxpayer Basis.

 

While Federal Prosecutors May Overlook State Marijuana Distribution Crimes, the IRS Will Not

As more states legalize the sale and use of marijuana, it has become a thriving billion-dollar business. Although such state laws violate federal criminal drug statutes, the Justice Department has turned a blind eye to enforcing those laws in states approving the use and sale of marijuana. But the IRS hasn’t. As a result, while operating marijuana dispensaries and selling marijuana may be legal businesses in California, Colorado, and other states, that doesn’t mean the expenses of operating those businesses are deductible for federal income tax purposes. This was made clear by the Ninth Circuit in Olive v. Comm’r, 2015 PTC 229 (2015), which affirmed a Tax Court holding that, while a taxpayer’s marijuana business was legal under California law, Code Sec. 280E precluded him from deducting any amount of ordinary or necessary business expenses associated with the business, other than cost of goods sold, because it was a trade or business consisting of trafficking in controlled substances prohibited by federal law.

For a full discussion of the Olive case, see
Pot Dealer's Appeal Goes Up in Smoke; Expenses of Medical Marijuana Business Aren't Deductible.

 

IRS Combats Identity Theft by Eliminating Automatic Extensions of Forms W-2 and Other Information Returns

Currently, Reg. Sec. 1.6081-8T allows an automatic 30-day extension of time to file information returns on forms in the W-2 series (including Forms W-2, W-2AS, W-2G, W-2GU, and W-2VI), 1095 series, 1098 series, 1099 series, and 5498 series, and on Forms 1042-S and 8027. An additional 30-day non-automatic extension of time to file those information returns is available in certain cases.

Effective July 1, 2016, in an effort to fight identity theft, the IRS will end the automatic extension of time to file information returns on forms in the W-2 series (except Form W-2G). The IRS also plans to end automatic filing extensions for all other information returns included under Reg. Sec. 1.6081-8T at a date no earlier than January 1, 2018.

For information returns on the Form W-2 series (except Form W-2G) due after December 31, 2016, a single non-automatic extension of time is available (Reg. Sec. 1.6081-8T(b)). For information returns on Forms W-2G, 1042-S, 1094-C, 1095-B, 1095-C, 1097 series, 1098 series, 1099 series, 3921, 3922, 5498 series, or 8027 due after December 31, 2016, one automatic 30-day extension of time to file the information return beyond the due date for filing it is available if the filer or the person transmitting the information return for the filer (i.e., the transmitter) files an application in accordance with Reg. Sec. 1.6081-8T(c)(1). One additional 30-day extension of time to file these forms may be allowed if the filer or transmitter submits an extension request before the expiration of the automatic 30-day extension of time to file. No extension of time to file will be granted unless the filer or transmitter has first obtained an automatic extension of time (Reg. Sec. 1.6081-8T(c)(2)).

For a full discussion of the elimination of the automatic extensions for Form W-2 and other information returns, see
IRS Ends Automatic Extension of W-2 Information Returns to Combat Identity Theft.

 

Proposed Regulations Take Aim at Pro-Taxpayer Decision Involving Code Sec. 199 Deduction

Under Code Sec. 199(a)(1), a taxpayer can deduct a portion of its qualified production activities income, which is determined from the taxpayer's domestic production gross receipts. Domestic production gross receipts are defined, in part, as proceeds from the sale of qualifying production property (QPP) which was manufactured, produced, grown, or extracted (MPGE) by the taxpayer in whole or in significant part within the United States.

Under Reg. Sec. 1.199-3(e)(2), if a taxpayer packages, repackages, labels, or performs minor assembly of QPP and the taxpayer engages in no other manufacturing, producing, growing, or extracting (MPGE) activities with respect to that QPP, the taxpayer’s packaging, repackaging, labeling, or minor assembly does not qualify as MPGE with respect to that QPP. Thus, no Code Sec. 199 deduction is available.

In U.S. v. Dean, 945 F. Supp. 2d 1110 (C.D. Cal. 2013), a district court concluded that an S corporation’s activity of preparing gift baskets was a manufacturing activity and not solely packaging or repackaging for purposes of Code Sec. 199. Thus, the S corporation was eligible for a Code Sec. 199 deduction. Subsequently, in Precision Dose, Inc. v. U.S., 2015 PTC 345 (W.D. Ill. 2015), another district court cited the decision in Dean and held that a company's business of selling unit doses of medicines involved the sale of QPP which was MPGE and the company thus qualified for the Code Sec. 199 deduction.

The IRS disagreed with the Dean decision and issued proposed regulations which add an example (Example 9) to Reg. Sec. 1.199-3(e)(2). While the example is based on the facts in Dean, it reaches the opposite conclusion as the Dean court and concludes that the taxpayer is not considered to have engaged in the MPGE of QPP. Thus, no Code Sec. 199 deduction is available.

For a discussion of the proposed Code Sec. 199 regulations, see
IRS Issues Proposed and Temporary Regs on Domestic Production Activities.

 

Steep Increases in Information Reporting Penalties Take Effect in January

Generally, any person, including a corporation, partnership, individual, estate, and trust, which has reportable transactions involving information returns and payee statements during the calendar year, must report those transactions to the IRS. Persons required to file information returns to the IRS must also furnish statements to the recipients of the income. A failure to file a required information return or payee statement, or a failure to include all necessary information, will subject taxpayers to penalties under Code Sec. 6721 or Code Sec. 6722.

In June, the President signed into law the Trade Preferences Extension Act of 2015 (Pub. L. 114-27). The new law enacted hefty increases in the penalties imposed under Code Sec. 6721 and Code Sec. 6722. For each information return or payee statement with respect to which a failure occurs, the penalty has been increased from $100 to $250, and the maximum penalty that may be imposed has increased from $1,500,000 to $3,000,000. These penalties are effective for returns or statements taxpayers are required to file after Dec. 31, 2015.

For a full discussion of the increased reporting penalties, see
Steep Increases in Information Reporting Penalties Set to Take Effect in January.

 

Final Rules on Changes in Partnership Ownership Interests Allow Different Methods to Be Used for Different Ownership Changes in the Same Year

In August, the IRS issued final regulations (T.D. 9728) on determining a partner's distributive share of partnership items of income, gain, loss, deduction, and credit when a partner's interest changes. The final rules provide a step-by-step process for making allocations and are important because the correct determination of a partner’s distributive share of partnership income is critical to determining that partner’s ultimate tax liability.

The final regulations make several favorable changes to the proposed regulations that had preceded them. Most notable is the ability of a partnership to use different methods for different ownership changes. Under the proposed regulations, a partnership had to take into account any variation in the partners’ interests in the partnership during the tax year in determining the distributive share of partnership items by using either the interim closing method or the proration method. Unless the partners agreed to use the proration method, the partnership was required to use the interim closing method and allocate its items among the partners in accordance with their respective partnership interests during each segment of the taxable year. The final regulations allow a partnership to use different methods for different variations within the partnership’s taxable year. Accordingly, a partnership may use the interim closing method with respect to one variation and may choose to use the proration method for another variation in the same year.

In addition, the proposed regulations had required partnerships applying the interim closing method to perform the interim closing at the time a variation in ownership was deemed to occur, and did not permit a partnership to perform an interim closings of its books except at the time of any variation. Because most partnerships lack the resources to close their books at other than month end, the final regulations allow a partnership, by agreement of the partners, to perform regular interim closings of its books on a monthly or semi-monthly basis, regardless of whether any variation occurs.

For a full discussion of the final rules on determining a partner’s distributive share when a partner’s interest changes, see
IRS Issues Final Regs on Determining Distributive Share When a Partner's Interest Changes.

 

Supreme Court Upholds Obamacare for a Second Time

On June 25, in King v. Burwell, 2015 PTC 210 (S. Ct. 2015), the Supreme Court upheld the use of tax credits for health insurance purchased on any Exchange created under The Patient Protection and Affordable Care Act (ACA), be it federal or state. Of the 380,000+ words that comprise the ACA, its fate under this case hinged on just six: "an Exchange established by the State."

The case involved Reg. Sec. 1.36B-2, which provides that a taxpayer is eligible for a premium tax credit if the taxpayer is enrolled in an insurance plan through "an Exchange," which the regulation defines as an Exchange serving the individual market regardless of whether the Exchange was established and operated by a state or by the federal government through Health and Human Services.

Hearing the appeal of four Virginia taxpayers who had challenged the validity of the regulation, the Supreme Court concluded that the ACA's context and structure compelled the conclusion that Code Sec. 36B allows tax credits for insurance purchased on any Exchange created under the statute.

Having survived what may be its last major challenge in the courts, the ACA's next existential challenge will likely come in the political arena, as numerous Republican presidential candidates and party leaders have vowed to make repeal of the ACA a central issue in the 2016 elections.

For a full discussion of the Supreme Court’s decision in King v. Burwell, see
Supreme Court Upholds Premium Tax Credits to Individuals in States with Federal Exchanges.

 

IRS Provides Transition Relief from Staggering $36,500 per Employee Healthcare Penalty

In February, the IRS issued Notice 2015-17, which provided transition relief though 6/30/2015 from the assessment of penalties under Code Sec. 4980D for small employers who reimburse or pay a premium for individual health insurance for an employee. The notice also stated that such penalties will not be assessed any earlier than 2016 against S corporations that have similar arrangements with 2-percent shareholder-employees (and then only if future guidance holds that the penalty applies in those situations).

The potential penalties are the result of an aspect of the Affordable Care Act (ACA) known as “market reforms.” In order to bring about the larger goals of healthcare reform, the ACA added Code Sec. 4980D, which applies a penalty to group health plans that fail to meet reform requirements such as providing certain preventative services without imposing cost-sharing arrangements and eliminating annual limits of benefits.

Under Notice 2013-54, employee payment plans (i.e., plans where employees choose their own insurance plans and employers reimburse the costs) are considered to be group health plans that fail to meet these market reforms. Employers who reimburse the health insurance premiums of their employees under such plans are subject to a $100 per day, per employee penalty under Code Sec. 4980D (reaching up to $36,500 per employee, per year).

Notice 2015-17 gave employers, other than applicable large employers with employee payment plans, an extra six months to comply with the ACA’s market reform requirements before incurring these staggering penalties.

For a full discussion of transitional relief under Notice 2015-17, see
IRS Ends Confusion Over Form 3115 Requirements, Provides Relief to Small Businesses.

 

Congress Reverses Supreme Court’s Home Concrete Decision

In U.S. v. Home Concrete & Supply, LLC, 2012 PTC 94 (S. Ct. 4/25/12), the Supreme Court held that taxpayer misstatements that overstate the basis in property do not fall within the scope of the Code Sec. 6501(e)(1) extended statute of limitations. That section extends the normal three year limitation period for assessments to six years where a taxpayer omits from gross income an amount in excess of 25 percent of the amount stated on the return.

The Court determined that an "understatement" of basis was not an "omission" for purposes of the statute. In reaching this decision, the Court looked at the legislative history of the provision and concluded that Congress intended an exception to the usual three-year statute of limitations only in a restricted type of situation - a situation that did not include overstatements of basis. As a result of the decision, the taxpayers were allowed to avoid certain taxes from their participation in a Son-of-BOSS transaction because the IRS didn't discover their overstated basis until after the normal three year period.

IRS Chief Counsel William J Wilkins had lamented that the decision would mean taxpayers in other unsettled Son-of-BOSS cases would likely prevail, given the difficulty of untangling such transactions within the three year limit.

In July, Congress effectively reversed the Supreme Court's holding. In the Surface Transportation and Veterans Health Care Choice Improvement Act of 2015 (Pub. L. 114-41), Congress amended Code Sec. 6501 to clarify that an understatement of gross income by reason of an overstatement of unrecovered cost or other basis is an omission from gross income for purposes of the six year statute of limitations.

 

IRS Delays Reporting of 2015 Health Insurance Information

Under Code Secs. 6055 and 6056, every person that provides minimum essential coverage to an individual during a calendar year must file Form 1095-B, Health Coverage, reporting the coverage. However, employers subject to the employer shared responsibility provisions sponsoring self-insured group health plans generally report information about the coverage on Form 1095-C, Employer-Provided Health Insurance Offer and Coverage, instead of Form 1095-B. The information on those forms is transmitted to the IRS on Form 1094-B, Transmittal of Health Coverage Information Returns, and Form 1094-C, Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns. For the 2015 calendar tax year, these returns were required to be filed by February 1, 2016.

In Notice 2016-4, the IRS extended the due dates for the 2015 information reporting requirements (both furnishing such reports to individuals and filing them with the IRS) on these returns. Specifically, Notice 2016-4 extends the due date (1) for furnishing to individuals the 2015 Form 1095-B and the 2015 Form 1095-C from February 1, 2016, to March 31, 2016, and (2) for filing with the IRS the 2015 Form 1094-B, the 2015 Form 1095-B, the 2015 Form 1094-C, and the 2015 Form 1095-C, from February 29, 2016, to May 31, 2016, if not filing electronically, and from March 31, 2016, to June 30, 2016 if filing electronically. Notice 2016-4 also provides guidance to individuals who might not receive a Form 1095-B or Form 1095-C by the time they file their 2015 tax returns. (Editorial Department Parker Tax Publishing)

Disclaimer: This publication does not, and is not intended to, provide legal, tax or accounting advice, and readers should consult their tax advisors concerning the application of tax laws to their particular situations. This analysis is not tax advice and is not intended or written to be used, and cannot be used, for purposes of avoiding tax penalties that may be imposed on any taxpayer. The information contained herein is general in nature and based on authorities that are subject to change. Parker Tax Publishing guarantees neither the accuracy nor completeness of any information and is not responsible for any errors or omissions, or for results obtained by others as a result of reliance upon such information. Parker Tax Publishing assumes no obligation to inform the reader of any changes in tax laws or other factors that could affect information contained herein.

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