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Compass
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New Jersey Individual Mandate Requires State Filings in March 2020
Proskauer [Guidance Overview] Oct. 25, 2019 "Currently, the existing IRS Forms 1094/5-B and 1094/5-C contain the information New Jersey needs to verify enrollment, and therefore, New Jersey is willing to accept those forms. However, New Jersey notes that if the IRS changes the forms, it is possible that the state will develop its own forms.... [As of Oct. 25, 2019,] the IRS has not issued draft Forms 1094/5-B or 1094/5-C for 2019. Given that 2019 is the first year without the ACA's individual mandate, it is possible that the IRS is developing significantly revised forms (and, hence, the delay)." |
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