IRS Releases 2017 Instructions for Forms 1094-C and 1095-C

Adam Rivera
October 9, 2017

The IRS has released the 2017 Instructions for Forms 1094-C and 1095-C. There are a couple of changes from their respective previous revisions:

Changes to 2017 Instructions for Forms 1094-C and 1095-C


  • Now there is no section 4980H transition relief available for 2017
    • The instructions have thus removed discussion of section 4980H transition relief, and Form 1094-C was also updated because of this
    • Specifically, Form 1094-C, line 22, box C is designated “Reserved”; Part III, column (e) is designated “Reserved”; and the entry rows in Part III, column (e) are shaded
  • New Instructions
  • Paper returns filed with the IRS must be printed in landscape format
  • Forms 1095-C filed with incorrect dollar amounts on line 15, Employee Required Contribution, may fall under a safe harbor for de minimis errors. This safe harbor generally applied if no single amount in error differs from the correct amount by more than $100. If the safe harbor applies, you will not have to correct Form 1095-C to avoid penalties. However, if the recipient elects for the safe harbor not to apply, you may have to issue a corrected Form 1095-C to avoid penalties.
  • Premium tax credit percentage increased to 9.69% for TY2017

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Adam Rivera

Adam Rivera is a member of the Regulatory Analysis Team’s Direct Tax division at Sovos. His main areas of focus are Federal and State Tax Withholding and Affordable Care Act (ACA) Reporting. Prior to Sovos, Adam worked as a legislative aide in the Florida House of Representatives. He also has experience in securities law, focusing on securities litigation and researching emerging crowdfunding methods of raising capital. Adam is a member of both the Massachusetts and Florida Bars. He earned his B.A. from the University of Florida and his J.D. from the University of Miami.
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