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Changes to the 2016 IRS Form 1094-C According to the Draft Instructions
Accord 
[Guidance Overview] Aug. 26, 2016
"First, and most importantly, the deadline for the Form 1094-C will be three or four months earlier in 2016 compared to 2015....[T]he penalty for the failure to file a correct information return (in this case the Form 1094-C) generally is $260 for each return for which a failure occurs.... [E]mployers no longer have the protection of the good faith effort standard in 2016.... One area that caused particular confusion in 2015 and is reemphasized in the instructions is the need for each applicable large employer member to file its own Form 1094-C."
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