What is an authoritative 1094-C?

An authoritative 1094-C form is a transmittal form that summarizes all of the 1095-C forms filed for the employer. The authoritative 1094-C will require Parts I, II, and III to be completed. Part IV of the form will be completed if the employer is part of an Aggregated ALE Group.

A non-authoritative 1094-C form summarizes only the 1095-C forms filed in a specific filing. Only Part I of the 1094-C form is completed when filing a non-authoritative 1094-C form.

The IRS requires that one authoritative 1094-C be filed per EIN per tax year. If all 1095-C forms for the employer are being filed at the same time, the 1094-C form that is filed with that batch of 1095’s should be the authoritative 1094-C.

Each member of an Aggregated ALE Group will need to file an authoritative 1094-C specifically for that ALE member.

Corporation X, Corporation Y, and Corporation Z are all part of an Aggregated ALE Group. Each company will need to file a separate authoritative 1094-C form that summarizes only the ALE Member (employer). Parts I, II, and III of the authoritative 1094-C for each ALE Member will summarize the information for that member; the form will not include information in these parts of the 1094-C from the other two companies. Only Part IV of the 1094-C will include information regarding other ALE Members. 

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