The robot apocalypse is a ways off (...or isn't it), but the IRS penalty machine is gearing up, and the order from Skynet is guilty until proven innocent. No, really. The more time we spend analyzing the newest IRS guidance and sample forms, the more it appears IRS is going to put employers on the defensive—all at a terrible time of year in the HR calendar and under the gun of short deadlines. Here's why we think that, plus some thoughts on how to prepare.Penalty Assessment ScenariosLine 16 Blank for Any One MonthBased on the sample Letter 226J IRS released, IRS is presuming an employer is liable for an employer shared responsibility excise tax (a/k/a pay-or-play penalty) if an employee got subsidized individual coverage on a state or federal exchange and that employee received a 1095-C on which line 16 is blank for any one or more months.
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