ACA Reporting Q&A – EINs (ScreenCast 03)
Question: We have a controlled group with lots of employees. Somehow we are able to use the same EIN on paychecks for every employee regardless of which entity employs them. Can I use this single EIN for all of my ACA reporting?
Answer: No. You might be relying on the common pay agent rules or the common paymaster rules to simplify paychecks and W-2s. But those rules don’t help you for ACA reporting. You will still need to use each separate ALE Member’s EIN on the 1094-C filed by that ALE Member and the 1095-Cs issued by that ALE Member.
ScreenCast. Click on the ScreenCast below for a related discussion with Tim Goodman and Bob Seng. The ScreenCast refers to an earlier episode by Bob Seng and Liz Deckman on terminology. You can find that one here. (Liz/Bob on ACA Terms). The 1094/1095-C instructions contain useful definitions. You can find them here. (IRS)