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Mail and E-File Reporting Requirements for Aggregated ALE with some EINs Less than 250 Forms


Yes, the employer information reporting requirements are applied separately to each ALE member comprising the ALE, consistent with the approach used to determine any assessable payment. For example, each ALE member is responsible for its own information reporting requirements, and is not responsible for the information reporting requirements of any other entity in the controlled group comprising the ALE. Therefore, if you are an ALE member with less than 250 Forms 1095-C, you can submit paper returns.

Below are the definitions needed. Click Here for a KB Article on Aggregate ALE and EIN

Aggregated ALE Group.

An Aggregated ALE Group refers to a group of ALE Members treated as a single employer under section 414(b), 414(c), 414(m), or 414(o). An ALE Member is a member of an Aggregated ALE Group for a month if it is treated as a single employer with the other members of the group on any day of the calendar month. If an ALE is made up of only one person or entity, that one ALE Member is not a part of an Aggregated ALE Group. Government entities and churches or conventions or associations of churches may apply a reasonable, good faith interpretation of the aggregation rules under section 414 in determining their status as an ALE or member of an Aggregated ALE Group.

Applicable Large Employer (ALE).

An ALE is, for a particular calendar year, any single employer, or group of employers treated as an Aggregated ALE Group, that employed an average of at least 50 full-time employees (including full-time equivalent employees) on business days during the preceding calendar year.

A new employer (that is, an employer that was not in existence on any business day in the prior calendar year) is an ALE for the current calendar year if it reasonably expects to employ, and actually does employ, an average of at least 50 full-time employees (including full-time equivalent employees) on business days during the current calendar year.


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Last Review: 5/27/2022 – Revision: 1.0

Applies To:  ACA Compliance Solution

Categories:  Year End – Prerequisites 1094-C

Keywords:  250, ALE

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