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  1. I would greatly appreciate anyone's insight on the below - The main question is what all entities are required to be included on part iv of Form 1094-C when a stock sale causes an entity to cease to be a member of one Aggregated ALE Group and become a member of second Aggregated ALE Group mid-year. A simple example scenario - SellCo is one of a number of a wholly-owned subsidiary of HoldCo and is an ALE Members of the "HoldCo Aggregated ALE Group". Mid-year HoldCo sells all of the stock of SellCo to BuyCo causing SellCo to become an ALE Member of the "BuyCo Aggregated ALE Group" (which assume includes other wholly owned-subsidiaries of BuyCo). What I am specifically wondering is for the subsequent 1094-C which all entities are required to be listed in part iv of the 1094-C filed by SellCo. (Other Ale Members of Aggregate ALE Group): All ALE Members of both the HoldCo Aggregated ALE Group and all ALE Members of the BuyCo Aggregated ALE Group, or only ALE Members of the BuyCo Aggregated ALE Group. I would greatly appreciate anyone's thoughts as I have come up empty handed on this (as well as any additional thoughts on whether this would impact the part III(d) Aggregated Group Indicator reporting.
  2. Our client just filed their 2019 1095-Cs with the IRS. They were overlooked back in the spring (an extension to May 1 was filed) due to COVID/PPP things, and we just realized they hadn't been filed last week. No letter has been received from the IRS. Technically, a penalty of $270 per record could be charged. But do any of you know if the IRS is actually assessing the penalty when the taxpayer files them on their own, without the IRS having to get involved? Please give us some good news! And yes, the forms were distributed to the employees timely.
  3. I am interested in others' interpretations of the IRS regulations and guidance on potential penalties for incorrect SSNs on Form 1095-C. Specifically, if an employer receives a TIN Validation Error when filing a 1095-C electronically, indicating there is a mismatch between an employee's SSN and Name in the IRS database (either a mismatch or no record), is the employer required to verify the SSN with the employee and make an attempt to correct the return, in order to demonstrate a good faith effort to comply (and thus avoid a penalty for failure to file a correct return)? Or is documentation of the initial receipt of the incorrect SSN from the employee enough to demonstrate good faith effort (i.e. a Form W-4)? Does the 2015 relief from penalties for filing incomplete or inaccurate information based on a "good faith effort" to comply mean that the regulations under 26 CFR 301.6724-1 pertaining to a waiver of penalties due to reasonable cause don't apply for 2015? Should an employer receiving a mismatch error notice thru the efile system verify the SSN with employee now, or wait until a formal penalty notice is received? I'm setting aside the myriad of immigration and discrimination issues this presents for purposes of this discussion. Any input or discussion would be greatly appreciated!!
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