Even though penalties for failure to comply with Affordable Care Act (ACA) coverage requirements have been in force since January 1, 2014 for employers with 100 or more full-time equivalent employees and January 1, 2015 for...more
Last summer, the Internal Revenue Service (IRS) announced that its periodic review of individually designed retirement plans to determine the plans’ qualified status will end effective January 31, 2017. In January 2016, the...more
Within the last week, there has been a flurry of activity from both Congress and the Internal Revenue Service (“IRS”) with respect to the Affordable Care Act (“ACA”). This client alert first reviews the delayed effective date...more
The Department of Labor (DOL) has clarified the fiduciary implications of an employee benefit plan investing in so-called “socially responsible investments,” sometimes referred to as “impact investments” or “economically...more
11/2/2015
/ Affordable Housing ,
Bond Financing ,
Construction Contracts ,
Construction Industry ,
Corporate Social Responsibility ,
Department of Labor (DOL) ,
Economic Development ,
Economically Targeted Investments ,
Job Creation ,
Multiemployer Plan ,
Project Finance ,
Union Membership
Despite guidance from the Internal Revenue Service (“IRS”), the Department of Labor (“DOL”) and the Department of Health and Human Services (“HHS”) indicating the prohibition of the practice under the Affordable Care Act...more
5/29/2015
/ Affordable Care Act ,
Department of Health and Human Services (HHS) ,
Department of Labor (DOL) ,
Employer Group Health Plans ,
Health Insurance ,
IRS ,
Medical Reimbursement ,
Penalties ,
Popular ,
S-Corporation ,
SHOP Program
Last week the U.S. Supreme Court issued its opinion in Tibble v. Edison International, a highly anticipated case involving whether ERISA’s six year statute of limitations for breach of fiduciary duty claims prevented a claim...more
Certain group health plans are required to obtain a 10-digit Health Plan Identifier ("HPID") from the Center for Medicare and Medicaid Services ("CMS") by November 5, 2014. Currently various users of the health care system...more
In June 2013, the US Supreme Court in Windsor v. U.S., ruled as unconstitutional the portion of the federal Defense of Marriage Act (“DOMA”) which provided that for federal law purposes, a marriage meant an opposite-sex...more
In This Issue:
- IRS ISSUES TRANSITION RELIEF ON THE ONE-YEAR DELAY IN ACA’S INFORMATION REPORTING AND EMPLOYER SHARED RESPONSIBILITY RULES:
On July 9, 2013, the IRS issued Notice 2013-45 which provides...more
On July 22, 2013, the DOL announced a temporary enforcement policy that provides the administrators of individual account retirement plans such as 40 (k) or 403(b) plans some additional flexibility regarding when they have to...more
Late on July 9, 2013, the IRS issued Notice 2013-45 which provides some additional information regarding the Department of Treasury’s recently announced delay in the information reporting and employer shared responsibility...more
On July 2, 2013, the Department of Treasury announced a one-year delay in the employer shared responsibility mandate under the Affordable Care Act (“ACA”) and related information reporting.
Complexity Leads to Delayed...more
On June 26, 2013, in U.S. v. Windsor, the US Supreme Court held the federal Defense of Marriage Act (“DOMA”) unconstitutional as a violation of the right to liberty found in the due process clause of the 5th Amendment to the...more
7/1/2013
/ COBRA ,
Due Process ,
Employee Benefits ,
Equal Protection ,
Health Insurance ,
Health Insurance Portability and Accountability Act (HIPAA) ,
Income Taxes ,
Retirement Plan ,
Same-Sex Marriage ,
SCOTUS ,
US v Windsor
On May 29, 2013, the Departments of Labor, Treasury and Health and Human Services released final regulations on nondiscriminatory wellness programs in group health plan coverage. The regulations largely follow the proposed...more
6/5/2013
/ ADEA ,
Affordable Care Act ,
Americans with Disabilities Act (ADA) ,
Department of Health and Human Services (HHS) ,
Department of Labor (DOL) ,
Equal Employment Opportunity Commission (EEOC) ,
GINA ,
Health Insurance Portability and Accountability Act (HIPAA) ,
Healthcare ,
U.S. Treasury ,
Wellness Programs