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Time to Get Serious About the ACA's Employer Reporting Requirements
McAfee & Taft 
[Guidance Overview] Oct. 2, 2014
"[T]he employer mandate reporting will be a two-step process: [1] reporting to the employee by January 31 of the following year; and [2] reporting to the IRS by March 31 of the following year (or February 28 if filing by paper).... Even though reporting will first be required in early 2016, you will need to start capturing the needed data beginning in January 2015."
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