Form 1094-C Correction

[Catsby]

Has anyone dealt with filing corrections for entities that filed Form 1095-Cs under the wrong entity? For example, entities A and B are part of the same controlled group. B pays this group of employees (and provides their Form W-2s), but their Form 1095-Cs were filed under entity A. This means that entity B has filed Form W-2s but no corresponding 1094-Cs or 1095-Cs, which is likely to trigger a letter from the IRS. 

Is there a way to correct this before the IRS sends the penalty letter? I read the Publication 5165 correction rules to say no - you need an original record to correct. In this case, there's no original record to correct. 

Anyone have experience with this? TIA!

 

[Flyboyjohn]

Sounds like you would not be filing "corrected" forms but instead would be filing "correct" forms late which will only serve to totally confuse the IRS 1094-C/1095-C processing systems.

Best to wait for the inquiry from IRS and be ready to promptly respond with the "correct" forms and highly likely IRS will abate any non-filing or late filing penalties.