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ACA Non-Reporting: IRS Letter 5699
HUB International
Sept. 26, 2018
"While it is not clear how the IRS identifies employers who might be subject to reporting, but didn't file, the IRS may be identifying potential non-filers from Form W-2 filings or other tax filings.... [S]eparate, and sometimes overlapping, reporting requirements for insurers and employers... has led to a few common misconceptions ... [1] We don't have 50 full-time employees, so these rules don't apply to us.... [2] Our employees are in separate companies, under separate tax ID numbers/EINs, and none of the companies is over the 50 full-time and full-time equivalent employee threshold, so these rules don't apply to us.... [3] We filed all our forms under one tax ID number/EIN.... [4] I'm fully-insured, so the insurer handled reporting for me."
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