Upcoming Employee Benefit Plan Deadlines

January 14, 2016

This client alert follows up on our prior alerts entitled "Employee Benefit Plan Filing Deadlines." The following are the most common applicable filing deadlines (and/or "Heads Up" for coming deadlines) or other important dates for January and February 2016 for calendar year plans:

January 15 – Deadline for the plan administrator of self-insured health plans to pay all or at least the first installment of the transitional reinsurance fee for 2015 ($44 per member based on reported November 15, 2015, headcount).

January 31 – Deadline for the plan sponsor to file Form 945 with the IRS to report income withheld during 2015 from distributions made to participants from qualified plans. (Note, if taxes were timely deposited with the IRS, the plan sponsor has an automatic extension until February 10, 2016, to file the Form 945.)

January 31 – Deadline for the payer to send Form 1099-R to participants, retirees and beneficiaries receiving distributions from qualified retirement plans.

January 31 – Deadline for the payer to send Form 1099-MISC to certain service providers or other recipients who receive direct payments of $600 or more from qualified retirement and health and welfare benefit plans for services, rent and specified other purposes.

January 31 – Deadline for employers to send employees Form W-2 (Wages and Tax Statement).

January 31 – Deadline for plan sponsor (with an EIN ending in zero or five) to file for an On-Cycle E determination letter for its individually designed qualified retirement plan.

January 31 – Original deadline for either small employers (with self-insured plans) or health insurance carriers to provide enrolled employees with Form 1095-B (Health Coverage), but deadline has been extended to March 31, 2016. (See our December 31, 2015, alert.)

January 31 – Original deadline for applicable large employers to provide employees with Form 1095-C (Employer-Provided Health Insurance Offer and Coverage), but deadline has been extended to March 31, 2016. (See our December 31, 2015, alert.)

February 1 – On-Cycle A determination letter for individually designed qualified retirement plans for plan sponsors (with an EIN ending in one or six) opens on this date (and will close January 31, 2017). Note this On-Cycle A filing will be the last on-cycle filing accepted by the IRS under its current "on-cycle" filing program.

February 14 – Deadline (45 days after the close of a plan year) for the plan administrator to provide statements to participants in a defined contribution plan with participant-directed investments for the quarter ending December 31, 2015.

February 14 – Deadline (45 days after the close of the plan year) for the plan administrator to provide participants or beneficiaries in a defined contribution plan with participant-directed investments the required annual disclosures of specified plan information and specified investment-related information, such as fees deducted from the participant’s or beneficiary's account. 

February 29 – Deadline for the payer or the employer to file IRS Forms 1099-R and 1099-MISC with the IRS. Note that this deadline can be extended until March 31, 2016, if filed electronically.

February 29 – Original deadline for Forms 1094-B and 1094-C transmittal forms to be sent to the IRS, but this deadline has been extended until May 31, 2015, (or if filed electronically, from March 31, 2016, to June 30, 2016). (See our December 31, 2015, alert.)

Please note that there are other deadlines which apply to the distribution of documents and notices to employees upon their employment or their termination of employment which are not addressed in this alert. If you have any questions regarding the deadlines listed in this alert or any other compliance deadlines, please contact  Donald S. Kohla at 678.336.7140 or Jan G. Marsh at 678.336.7135.

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