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
6/24/2021
/ American Rescue Plan Act of 2021 ,
COBRA ,
Employee Benefits ,
Employer Group Health Plans ,
Flexible Savings Accounts (FSAs) ,
HRA ,
Internal Revenue Code (IRC) ,
IRS ,
New Guidance ,
Premium Subsidies ,
Tax Credits
As the COVID-19 global pandemic continues to impact employers, the IRS has been looking for ways to provide some additional flexibility to employer-sponsored benefit plans. In the past week, the IRS released two notices aimed...more
On July 17, the IRS issued Notice 2019-45 (the Notice), expanding the concept of preventive care to certain services and items that target specific chronic conditions, such as testing strips and insulin for diabetes. As...more
On March 5, 2018, the Internal Revenue Service (IRS) released Rev. Proc. 2018-18, which changes the family limit on annual contributions to Health Savings Accounts (HSAs). The Revenue Procedure announced that the HSA limit...more
In a 6-3 decision on June 25, 2015 in King v. Burwell, the U.S. Supreme Court held that tax credits are available under the Patient Protection and Affordable Care Act (Affordable Care Act or PPACA) to all eligible Americans,...more
6/29/2015
/ Affordable Care Act ,
Chevron Deference ,
Health Insurance ,
Health Insurance Exchanges ,
Individual Mandate ,
IRS ,
King v Burwell ,
SCOTUS ,
State Health Insurance Exchanges ,
Statutory Interpretation ,
Subsidies ,
Tax Credits
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
On Friday, the U.S. Supreme Court announced that it would review the U.S. Court of Appeals for the Fourth Circuit’s decision in King v. Burwell. In that case, the Fourth Circuit held that tax credits for health insurance...more
11/12/2014
/ Affordable Care Act ,
Employer Mandates ,
Halbig v Burwell ,
Health Insurance ,
Health Insurance Exchanges ,
IRS ,
King v Burwell ,
Popular ,
SCOTUS ,
Subsidies ,
Tax Credits
On October 23 and 24, the Internal Revenue Service (IRS) and the Department of Labor (DOL) issued coordinated guidance on lifetime income provided through target date funds held by retirement plans. According to an...more
The Internal Revenue Service (IRS) recently issued Notice 2014-49 which describes a proposed approach for determining an employee’s full-time or part-time status for purposes of the employer shared responsibility rules under...more
On September 18, the Internal Revenue Service (IRS) issued Notice 2014-54, which clarifies that, subject to some limitations, a single distribution of pre-tax and after-tax amounts from a qualified retirement plan, a 403(b)...more
The Internal Revenue Service (IRS) and the Department of Treasury (Treasury) have issued final regulations under section 162(m)(6) of the Internal Revenue Code of 1986, as amended (Code), which limit the deduction certain...more
The Internal Revenue Service has issued Notice 2014-55 to permit new health plan elections in two situations where they were not previously allowed. ...more
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
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
Until now, those who used the Department of Labor’s Delinquent Filer Voluntary Compliance Program (DFVCP) to obtain relief from penalties for failing to timely file Form 5500 automatically qualified for relief from the...more
On April 3, 2014, the Internal Revenue Service released Revenue Ruling 2014-9 (the Ruling), which provides guidance helpful to the administration of rollovers by tax-qualified retirement plans by...more
On April 4, 2014, the Internal Revenue Service (IRS) released Notice 2014-19, which provides a series of Q&As regarding the application of the U.S. Supreme Court’s decision in United States v. Windsor and the IRS’s prior...more
On February 6, 2014, the Internal Revenue Service (IRS) proposed new regulations for calculating the unrelated business taxable income (UBTI) of IRC section 501(c)(9) voluntary employees’ beneficiary associations (VEBA) and...more
On November 26, 2013, the U.S. Department of Labor (DOL) updated its Semi-Annual Regulatory Agenda. This publication takes the form of a Federal Register notice to comply with certain administrative requirements. The DOL’s...more
On August 29, the U.S. Department of the Treasury (Treasury) and the Internal Revenue Service (IRS), following the U.S. Supreme Court’s decision in United States v. Windsor, jointly announced the issuance of Revenue Ruling...more
The principal regulators of U.S. employee benefits have recently published updates to their guidance plans for the coming months.
- On July 3, 2013, the U.S. Department of Labor (DOL) updated its Semi-Annual Regulatory...more
On July 9, the Internal Revenue Service (IRS) released Notice 2013-45 (the Notice), granting transition relief from the “Employer Shared Responsibility” provisions and certain health plan reporting requirements under the...more
7/12/2013
/ Affordable Care Act ,
Deadlines ,
Delays ,
Employer Mandates ,
Healthcare ,
IRS ,
Pay or Play ,
Penalties ,
Shared Responsibility Rule ,
Transition Relief ,
U.S. Treasury
The Internal Revenue Service (IRS) has released proposed regulations on the health insurer fee under section 9010 of the Patient Protection and Affordable Care Act (PPACA). The regulations, which were published in the Federal...more
The Internal Revenue Service (the Service) recently released PLR 201310043 (December 11, 2012), which addresses account - opening bonuses credited to an individual retirement account (IRA) or section 529 college tuition...more
In 2012, the Department of Labor (DOL) continued a fairly active program of issuing individual exemptions from the prohibited transaction rules of ERISA. These rules generally prohibit, among other things:
- Sale and...more