Today, the IRS formally recognized that employers (and state workforce agencies) need more time to adjust to the WOTC-program changes initiated by the Protecting Americans from Tax Hikes Act of 2015.
This morning, the IRS issued Notice 2016-40, which extends transition relief for another three months. At about the same time, the Department of Labor also issued Training and Employment Guidance Letter Number 25-15, dealing with the same issues.
Back in March, the IRS issued Notice 2016-22, which temporarily modified the normal 28-day application deadline for WOTC applications. That notice established June 29th as the grand-deadline to submit applications for all employees hired from January 1, 2015 through May 31, 2016.
Built into that schedule, however, was anticipation that the Department of Labor would issue updated WOTC forms in a timely manner. Employers and state workforce agencies would need time to adjust their procedures and technology to handle all the changes.
This morning, however, we found ourselves just 12 days away from that original deadline, still waiting for the updated forms. Happily, the new ETA forms are referenced in this mornings Guidance Letter. So I anticipate having them soon — probably later today.
Nevertheless, 12 days is not enough time to make this work. We now collectively have been granted until September 28th to get our systems into working order and to submit all outstanding applications.
This deadline extension applies to employees hired January 1, 2015 through August 31, 2016. Other than extending the time frames of transition relief, the recent notice does not otherwise modify the terms of the original IRS Notice 2016-22.