Affordable Care Act, New Guidance, IRS

Caution! Contents Hot: Key Benefits Issues to Watch During the Remainder of 2024

Bass, Berry & Sims PLC on 4/10/2024

While the sweltering roil of temporary regulatory changes related to the COVID-19 pandemic may have cooled and the initial burst of SECURE 2.0 steam begins to dissipate, sponsors of employee benefit plans should keep their...more

‎2024 Healthcare Affordability Percentage Makes Benefits More Expensive for Employers‎

Schwabe, Williamson & Wyatt PC on 8/28/2023

The employee benefits 2024 open enrollment season is quickly approaching and, with newly released IRS guidance, employers should be careful to ensure the health plan they offer employees is considered affordable. According to...more

Incentives: From Water Bottles To “Not So Substantial”

Jackson Lewis P.C. on 6/2/2021

For years (and we do mean years), the EEOC has waffled about whether incentives were permissible in connection with a medical inquiry under a voluntary wellness program. Friday, the EEOC issued its most recent pronouncement...more

An IRS Holiday Gift: 2019 Affordable Care Act Reporting Relief

Ogletree, Deakins, Nash, Smoak & Stewart,... on 12/11/2019

The Internal Revenue Service (IRS) issued Notice 2019-63 on December 2, 2019 providing some relief from Affordable Care Act (ACA) reporting requirements. The notice provides relief consistent with that provided in the past...more

IRS Issues Additional Guidance Issued on Health Reimbursement Arrangements

Ballard Spahr LLP on 11/21/2018

The IRS has followed up on its recently proposed Health Reimbursement Arrangements (HRA) regulations with guidance on some open issues. Notice 2018-88 specifically addresses the interplay between HRAs and two Internal Revenue...more

DOL Issues Guidance Regarding Interaction Between Affordable Care Act And Fringe Benefit Requirements Under Service Contract,...

Proskauer - Government Contractor Compliance... on 5/2/2016

The Davis Bacon Act and the Davis Bacon Related Acts (collectively “DBRA”) and the Service Contract Act (“SCA”) impose additional obligations related to fringe benefits and wages on covered contractors. With the passing of...more

IRS Provides Guidance on Suspension of Medical Device Excise Tax

Latham & Watkins LLP on 3/25/2016

Guidance eases tax filing burdens on medical device manufacturers. On February 24, 2016, the Internal Revenue Service (IRS) published informal guidance on the suspension of the Medical Device Excise Tax through an update...more

If You Blinked You Might Have Missed Important Affordable Care Act Guidance

Snell & Wilmer on 2/26/2016

Notice 2015-87 issued by the IRS on December 16, 2015, provides guidance on numerous Affordable Care Act provisions. Below are some of the highlights....more

IRS Notice 2015-87 (Part 1) – IRS Issues New HRA Integration Rules

Proskauer - Employee Benefits & Executive... on 12/22/2015

On December 16, 2015, the Internal Revenue Service issued Notice 2015-87 containing guidance on a wide-range of topics under the Affordable Care Act (ACA). In addition to providing guidance on affordability and COBRA matters...more

Compensation and Benefits Insights – September 2015

King & Spalding on 10/1/2015

The Patient Protection and Affordable Care Act (“ACA”)’s 40% excise tax on high-cost employer-sponsored health coverage (commonly known as the “Cadillac tax”) is slated to take effect in 2018. The IRS has issued several...more

Further Guidance on the ACA’s Cadillac Tax

McDermott Will & Emery on 9/30/2015

The Affordable Care Act (ACA) added Code Section 4980I to the Internal Revenue Code. Effective for tax years beginning on or after January 1, 2018, an excise tax of 40 percent will be imposed on the cost of employer-sponsored...more

The ERISA Litigation Newsletter - September 2015

Proskauer Rose LLP on 9/29/2015

Editor's Overview - It has been a little more than one year since the U.S. Supreme Court altered the legal landscape for litigating ERISA breach of fiduciary duty claims relating to the investment in employer stock...more

The (Poorly Named) “Cadillac Tax” Part Two: IRS Provides Further Guidance in Notice 2015-52

Alston & Bird on 9/23/2015

The so-called “Cadillac Tax” (Internal Revenue Code Section 4980I) applies starting in 2018 and was intended to provide a means to address what were perceived as overly rich employer-provided health benefit plan designs, as...more

New IRS Guidance on 40% Excise Tax Previews Future Regulatory Complexity

Proskauer - Employee Benefits & Executive... on 8/3/2015

Although public opposition to the 40% excise tax on high-cost health care is rapidly growing, the IRS continued to develop a regulatory framework for administration of the excise tax through its issuance of Notice 2015-52 on...more

IRS Notice 2015-43 Addresses Expatriate Health Coverage

Ogletree, Deakins, Nash, Smoak & Stewart,... on 7/13/2015

New guidance from the Internal Revenue Service (IRS) leaves in place the limited Affordable Care Act (ACA) exemptions set out in the Expatriate Health Coverage Clarification Act of 2014 (EHCCA). IRS Notice 2015-43 (Notice)...more

IRS Traded in Your Chevy for a “Cadillac (ac-ac-ac-ac-ac) Tax”: Agency Issues First Guidance on the Implementation Code Section...

Ogletree, Deakins, Nash, Smoak & Stewart,... on 4/23/2015

On February 23, 2015, the Internal Revenue Service (IRS) issued the first piece of guidance that discusses the excise tax, better known as the “Cadillac Tax,” imposed by Section 4980I of the Internal Revenue Code of 1986, as...more

IRS Lessens Reporting Burden on Charitable Hospitals

Lowndes on 3/13/2015

This week, the IRS issued new guidance for charitable hospitals that are required to disclose the failure to meet the requirements imposed by the Affordable Care Act. This new guidance is meant to lessen the burden on such...more

The Dangers of Reimbursing Employees for Individual Health Insurance Premiums--and the Limited Relief for Small Employers

Hinshaw & Culbertson LLP on 3/4/2015

Prior to the passage of the Affordable Care Act ("ACA") in 2010, employers were able to reimburse their employees for the premiums those employees paid for individual health insurance. This long-standing practice was changed...more

IRS Issues Preliminary Guidance on Cadillac Tax

Ballard Spahr LLP on 2/26/2015

Monday, the Internal Revenue Service issued preliminary but much-anticipated guidance on the so-called Cadillac tax imposed by the Affordable Care Act (ACA). The new notice offers very few concrete answers to employer...more

Premium Reimbursement Arrangements Get Relief - More ACA Transition Relief—This Time for Small Employers and S-Corps

Davis Wright Tremaine LLP on 2/26/2015

The IRS issued guidance on Feb. 18, 2015, providing temporary relief until June 30, 2015, from steep penalties for small employers and S-corps that have continued to use premium reimbursement arrangements to provide health...more

Patient Protection and Affordable Care Act (PPACA) › New Guidance › Internal Revenue Service

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