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COBRA subsidy strikes again with IRS guidance in Notice 2021-31

The American Rescue Plan Act (the Act) included certain temporary COBRA subsidy provisions that allow “Assistance Eligible Individuals” (AEIs) to receive COBRA subsidies from April 1, 2021 to September 30, 2021 (the...more

Texas v. United States decision could impact employer-sponsored health plans

On December 14, 2018, a Texas District Court ruled that the Affordable Care Act’s (ACA) requirement that certain individuals maintain a minimum level of health coverage, often referred to as the “Individual Mandate,” is...more

Legal Alert: IRS Offers Rules of the Road for Cadillac Plan Tax

On February 23, the Internal Revenue Service (IRS) issued Notice 2015-16 (Notice), which describes several possible approaches for implementing the excise tax on high-cost employer-sponsored health care plans (also known as...more

IRS Finalizes Guidance on Rev. Rul. 81-100 Group Trusts, and Insurance Company Separate Accounts

In Rev. Rul. 2014-24, scheduled for publication on September 8, 2014, the Internal Revenue Service (the Service) substantially completed its pending guidance on Rev. Rul. 81-100 group trusts by permanently authorizing the...more

IRS Releases Additional Rulings on Lump-Sum Windows

The practice of offering lump-sum distributions has become increasingly popular among defined benefit plan sponsors looking to decrease volatility or other defined benefit plan risks. In some situations, plan sponsors offer...more

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