Affordable ble Car Care A Act ct Rep eporti ting g Forms - PowerPoint PPT Presentation

Affordable ble Car Care A Act ct Rep eporti ting g – Forms orms 109 094 & & 1095 095 February 2, 2016 Kathy D. Petrucci & Zachary Davis 614-586-7214 614-586-7235

Firm Overview Since ce 1956, 956, S Schn chneider D Downs & Co. o., I Inc. provides a s accounting, t , tax, x, and bus usiness a advisory y services t to a num number o of compani nies i in n varyi ying ng i ind ndus ustries. – Ra Ranked a as on one of of the he 55 55-lar argest a account nting ing and nd bus usine ness a advisory f y firms i in n th the U U.S.; – Fourth-la largest c certified p publi lic a accounting and nd bus usine ness a advisory f y firm in n Western P PA and nd ni nint nth l largest in n Columb mbus, O OH.; – Fou ounded i in 1956 956 with r rapid growth h over t the he past 35 35 years, fr from om 50 50 employees i in 1980 980 to nearly 400 400 tod oday, i incl cluding 38 38 sha hareholders; – Active ind ndus ustry s y service g group ups inc nclud ude: Manufactu turing, D Distr tributi tion, C Constr tructi tion a and Real Es Esta tate, Aut utomobile D Dealerships, Ene Energy y and nd R Resour urces, Transportat atio ion, n, N Nonprofit it, H Higher E Educat atio ion a n and G Governm nment ntal al Services. Schneider Downs 2 ACA Forms 1094 & 1095 Webinar

About Your Presenters Kathy P Petru rucci is a a tax s share rehol older r in o our Columbus O s Ohio o office. She has 22 2 years o of • experi rience i in tax advi visor sory servi vices a s and has e extensi sive e experi rience w work rking with a a diversi rsified number r of indust stri ries, s such a as autom omotive, i insu sura rance, m manufacturi ring, transporta tation, and n not-fo for-profit fit. . Educati tion: B.S., A Account unting ng - Otterb rbein C College Mast ster r of Taxation on, C Capital U Universi rsity Law Scho hool Zack Davi vis i s is a a tax m manager i r in our C Columbus Ohio o o office. He has s 7 years rs of of • experi rience in t tax a advi visor sory servi vices a s and has extensi sive e experi rience w work rking with indust stry sectors ors ranging f from om c const stru ruction on, manufacturi ring, r real estate, h hospi spitality and t technology gy. Educati tion: B.S., A Account unting ng – Case West stern rn R Rese serve U Universi sity Mast sters of Account untanc ncy – Specializing in Taxation on, C Case West stern rn R Rese serve U Universi sity Schneider Downs 3 ACA Forms 1094 & 1095 Webinar

Agenda • Brief ef o over erview o of ACA Emplo loyer S Shared R ed Responsibili lity y requir irement a t and P Penal altie ies • ACA Repor ortin ting R Requir irement – Du Due Da Dates – When a and H How to o File le – What I Inf nformation is Need Needed ed f for Form R Rep eporting – Form 1 1095 095-C C Prepar aration T Tip ips s & Exam amples – Form 1 109 094-C Pr Prep eparation T Tips – Form 10 1094-B & 1 1095 095-B B Brief ef O Over ervi view – Rep eporting No Non-compli lianc nce P Penalties – Act ction S Step eps • Q & & A A Schneider Downs 4 ACA Forms 1094 & 1095 Webinar

Employer Shared Responsibility – IRC 4980H • The The ‘e ‘employer shared r d respo ponsib sibil ilit ity’ is t the he re requirement t tha hat Applicable le L Large E Emplo loyers ( (ALE LEs) offe fer healt lth i h insura rance t to the heir fu full ll-time e emplo loyees, an and d their de depe pendents t to ag age 2 26. – A large em e employer er i is an n em employer er w who has 50 o 50 or more e full ll-time ime emplo loyees, i inclu luding f full ll-time eq e equi uivalen ent em employees ees. – Mus Must l look at ent entities es und under er co common o owner nership a and nd i incl nclude e those em e employees ees i in n the e co count unt! – Ef Effect ective d e date e – 1/ 1/1/ 1/15. • However, large ge em employers who have 5 50 – 99 empl ployees ha have been een g given en a an addi ditional year t to c comply. Ther eref efore, t they a are required d to offer er cover erage ge begi ginning in 2016. Schneider Downs ACA Forms 1094 & 1095 Webinar

Employer Shared Responsibility – IRC 4980H • Comm mmon O Ownership hip – In determ rmining w whethe her a r a company i y is subject t to the Emplo loyer S Share red R Responsibility r y require rement, t , two o o or mo more c compan panies t that h have commo mmon o ownership p may ay b be treated a as a single le e emplo loyer – All e ll employees of of such c h com ompanies m must b be cou ounted i in the determination on o of larg rge e emplo loyer r if f the c compan anie ies f s form a m a controlled g group o p or af affil iliated se service g group u unde der I IRC Sectio ions s § 414(b (b), (c (c), (m (m), a and (o (o) Schneider Downs ACA Forms 1094 & 1095 Webinar

Employer Shared Responsibility – IRC 4980H Ther ere a e are f e four p primary t y types pes o of comm mmon o n owne nership gro roups: • Parent nt-su subsid sidiar iary c contr trolled g grou oup One ne c corpo poration o owns ns directly a at l least 8 80% of the voting po power o or value ue of ano nother – corpo poration All other corpo porations of which 80% o of voting po power or value ue o of stock owne ned b by – another memb mber i is i included in t the grou oup • Bro rother-sist ister c contr trolled g grou oup A group up o of two or more compa panies w where f five o or fewer common owne ners (inc ncluding – indivi viduals, estates, or trusts) o own dire rectly or indirectly (through t h the attri ribution r rules und under the Co Code) a a “cont ntrolling int nterest” ( (at l least 80%) of each g group up and nd h have “effective c con ontrol ol” (mor ore t than 50%) • Combin ined g grou oup (com ombin inat ation ion of t two a o above) • Affil ilia iated s servic ice gro roups Generally e entities con onnected by y management or or other s services – Schneider Downs ACA Forms 1094 & 1095 Webinar

Employer Shared Responsibility - Penalties Sect ction 4980H 4980H(a (a) – Payment nt/Penal nalty • – Empl ployer ers t that don on’t of offer insurance co coverage t to o 95% 95% (70% f (70% for or 20 2015) 5) of of full ll-ti time e me emp mployees ees ( (FTEs Es) w will be s subject t to o a penalty of of $2, $2,00 000 t 0 times the he employer’s r’s to total number o of F FTEs i if an em empl ployee r rec ecei eives a a pr premi emium t tax credi dit. (N (Note: F For or 20 2015, 5, exclude t the f first 80 80 FTEs. In 20 2016, 6, exclude t the f first 30 30 FTEs.) s.) Sect ction 4980H 4980H(b) – Payment nt/Penal nalty • – Coverage o offered, but c coverag age d doesn’t provid ide “min inim imum v val alue” o or is isn’t “affordable”. P “a Pen enalty o of $ $3,000 per per em empl ployee r rec ecei eiving pr premi emium tax cred edit. – Afford rdable le – Empl ployee pr prem emium m for l lowes est-cost o of se self lf-on only c coverage cannot e exceed 9. 9.56% 56% of of the employee’s h hou ouseho hold i incom ome f for or the year (usi sing any sa safe-harbor or m method od). ). – Min inim imum v value – must c cover at lea east 6 60% o of h hea ealthcare c costs e expec pected und nder p plan an Schneider Downs ACA Forms 1094 & 1095 Webinar

Large Employer Reporting Requirement • Begi ginn nning ng in in 2016, f 6, for 2015 r 5 reporting p period, , large emplo loyers (and s d small s ll self lf-ins nsure ured e employers) a ) are requir ired to f file le form rms that wi will b be e used b by t y the he I IRS RS t to det eter ermine i e if pen enalt lties u under der t the e e emplo loyer s shared d resp spon onsib sibil ility ity p provisio ision a apply a and i if employees s can recei eive p prem emium t tax c x credi edits. • Inclu ludes es l large e emplo ployer ers w with 5 50 to 99 emplo ployees es even thou ough t the e employer shar ared r respon sponsib sibil ility ity provision ision d doe oes s not a t apply for 2 2015! Schneider Downs ACA Forms 1094 & 1095 Webinar

ACA Reporting - Decision Tree 50 FTEs on File Form 1095-C & YES Self-Insured YES avg. for 2015 Complete Part III NO File Form 1095-C, NO Part III N/A Member of Self-Insured YES ALE Group File Form 1095-C & YES Complete Part III NO NO * 1095-B eligible for some non-employees At least 1 Full- Self-Insured NO File Form 1095-C, Time E’ee in Any YES Part III N/A Month of 2015 YES NO File Form 1095-B for No Reporting E’ees with minimum Requirement essential coverage Schneider Downs ACA Forms 1094 & 1095 Webinar