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IRS letters to suspected 2015 ALEs

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IRS has started notifying employers it suspects were Applicable Large Employers for 2015 but who have not filed 2015 Forms 1094-C and 1095-C (see redacted letter 5699 attached).

I'm wondering what "records" iRS used to make this determination, perhaps the filing of a threshold number of W-2s in 2014 that might indicate ALE status for 2015?

IRS Letter 5699 Request for 2015 Forms 1095-C_15342356(1).PDF

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