On March 5th, 2014, the Treasury Department and the IRS issued two final reporting rules of critical importance to employers...more
The Treasury Department and Internal Revenue Service recently issued final regulations implementing the employer shared responsibility provisions of the Affordable Care Act. For “applicable large employers” — i.e., those with...more
A January 18th New York Times article (Rules for Equal Coverage by Employers Remain Elusive Under Health Law) reported on the progress, or lack thereof, of the adoption of group health plan non-discrimination regulations...more
Breaking with long standing tradition—i.e., issuing important rules on a Friday before a holiday weekend, or (failing that) any Friday (hence the reference to Week 45½ in this post)—the Treasury Department and the IRS today...more
So where are they?
Final regulations implementing the Affordable Care Act’s rules governing shared responsibility of employers were widely expected to have “dropped” before the beginning, or perhaps during the first...more
(Note: This is the first installment of a series of entries that Alden will be posting each week for the next 51 weeks as he counts down to the January 1st, 2015 ACA pay-or-play deadline).
The IRS’s Employee Plans Compliance Resolution System (or “EPCRS”) permits corrections, both voluntary and on audit, of a broad range of “qualification failures” — i.e., violations of sometimes arcane and complex tax rules —...more
In addition to imposing substantive requirements on health insurance issuers in the group and individual markets and employer-sponsored group health plans, the Patient Protection and Affordable Care Act (Act) imposes three...more
On September 13, 2013, the Department of Labor and the Treasury Department/IRS (the “Departments”) issued coordinated guidance on a handful of items relating to the implementation of the Affordable Care Act (the “Act”),...more
In recently issued Revenue Ruling 2013-17, the Treasury Department and the Internal Revenue Service (IRS) ruled that all legal same-sex marriages will be recognized for federal tax purposes. The revenue ruling was accompanied...more
On July 9, less than a week after the Obama administration announced a one-year delay in the enforcement of the employer shared responsibility (aka “pay-or-play”) rules,1 the IRS has issued guidance making the move official....more
A key policy goal of the Patient Protection and Affordable Care Act (the “Act”) is the expansion of health insurance coverage to all Americans. The concepts of “minimum value” and its correlate “actuarial value” speak to the...more
In a set of Frequently Asked Questions (FAQs) posted to the Department of Labor’s website on January 24, the Departments of Health and Human Services, Labor, and Treasury (the “Departments”) put a stop to an approach to...more