Labor & Employment Tax Insurance

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News & Analysis as of

How Does the Supreme Court’s Obergefell Decision Affect Your Employee Benefit Plans?

The short answer: No plan amendments are required, but certain plan amendments and operational changes are permitted, and certain operational changes may be required....more

Health and Welfare Plans: Big Compliance Burdens, Big Penalty Exposures

Health and welfare have been around for a long time, and they are ubiquitous. Employees have come to expect medical, dental, life, and other insurance as part of their benefits packages. Employers offer coverage in order to...more

FAQs Regarding the ACA’s Employer Reporting Requirements (Part 1 of 2)

The employer reporting requirements under The Patient Protection and Affordable Care Act (the "ACA") are generally effective beginning January 1, 2015, with the applicable reports filed in early 2016. The purpose of the...more

Integrated Health Reimbursement Accounts, Coordination with Family Coverage, and Notice 2015-87—Something’s Missing

Issued at the end of last year, Notice 2015-87 provided detailed guidance on a host of topics. The notice has been referred to colloquially in some quarters as the “pot luck” notice. Among other things, the notice, in Q&A 4,...more

Staffing agency workers and ACA offers of coverage

The final regulations on the Affordable Care Act’s (ACA) “pay or play” rules were released on Feb. 10, 2014. Under the rules, there are potential penalties imposed on large employers that do not offer substantially all...more

The Affordable Care Act's Reporting Requirements

The Patient Protection and Affordable Care Act (“ACA”) commonly known as “Obamacare” created new reporting obligations in 2015 requiring most employers to report certain information to the Internal Revenue Service (“IRS”)...more

HRA Access for Spouses and Dependents: A New Wrinkle for Form 1095-C

Imagine that you are filling out Internal Revenue Service Form 1095-Cs for 2015 for an employer that offers employees the opportunity to elect self-only or family coverage under a minimum value group health plan. The plan...more

Issue 98: Year-End Agency FAQs Address Many Unanswered ACA Concerns

This is the ninety-eighth issue in our health care reform series of alerts for employers on selected topics in health care reform. This series of Health Care Reform Management Alerts is designed to provide a more in-depth...more

DOL and Treasury Update 2015-2016 Regulatory Agendas for Employee Benefits

The principal regulators of U.S. employee benefits have recently published updates to their guidance plans for the coming months. On November 19, 2015, the U.S. Department of Labor (DOL) updated its Semi-Annual...more

Congress Engages in Some Holiday Spending on Benefits

Congress’s recent $1.8 trillion holiday shopping spree (aka The Consolidated Appropriations Act, 2016, which became law on December 18, 2015) included a few employee benefit packages. We recently unwrapped the packages....more

Cadillac Tax Effective Date Postponed (and Three Other 2015 Year End Health and Welfare Benefits Legislation Highlights)

While Americans everywhere were busy eating turkey and drinking eggnog last November and December, our government was hard at work attending to budget matters. Tucked among the appropriations were several fairly significant...more

IRS Extends Affordable Care Act Reporting Deadlines

Last week, the Internal Revenue Service (IRS) granted a reprieve of sorts with respect to the 2015 information reporting requirements under the Affordable Care Act (ACA). Under the ACA, an “applicable large employer”...more

Alert: Affordable Care Act (ACA) End of Year Checklist

With the Affordable Care Act (“ACA”) nearly fully implemented and agency enforcement now underway, employers must be clear which provisions of the ACA apply to them. Any employer that sponsors a health plan for employees is...more

President Obama Approves the Consolidated Appropriations Act with Key Employee Benefits Provisions

The Consolidated Appropriations Act to fund the government through 2016 was passed and enacted on December 18. The law contains a number of benefits-related provisions, including a two-year delay of the 40-percent excise tax...more

IRS Extends The Due Dates For 2015 Information Reporting Under Sections 6055 And 6056 In IRS Notice 2016-4

"This notice extends the due dates for the 2015 information reporting requirements (both furnishing to individuals and filing with the Internal Revenue Service) for insurers, self-insuring employers, and certain other...more

Happy New Year from the IRS!

For the many employers and health care providers that have thus far been spending their holidays poring over the Affordable Care Act’s (ACA) new tax forms and their cryptic instructions in anticipation of the inaugural round...more

The Affordable Care Act’s Reporting Requirements for Carriers and Employers (Part 24 of 24): 5 Predictions

This post concludes our half-year series of posts focusing on the Affordable Care Act’s reporting requirements. These requirements are challenging in the extreme. Carriers and employers, and their vendors, service providers...more

2016 Filing and Notice Deadlines for Qualified Retirement and Health and Welfare Plans

Employers and plan sponsors must comply with numerous filing and notice deadlines for their retirement and health and welfare plans. Failure to comply with these deadlines can result in costly penalties. To avoid such...more

Cadillac Tax Delayed to January 1, 2020; Extension of ACA Health Plan Information Reporting Due Dates

After employer and other stakeholder opposition to the “Cadillac Tax” grew into bipartisan support from Congress, President Obama signed into law a two-year delay of the Cadillac Tax on December 18, 2015. This two-year delay...more

Does Your Cafeteria Plan Need to Be Amended Before Year-End?

As background, before 2014, an employee’s election to enroll in his or her employer’s health plan pursuant to a cafeteria plan was irrevocable for the entire plan year, unless the employee incurred an event that affected his...more

IRS Provides Some Deadline Relief on ACA Reporting and Furnishing Deadlines

Relief Only Applies for the 2015 ACA Coverage Offered and Provided Reporting to the IRS and Furnishing of Statements to Employees - While others may have thoughts of holiday cheer in their heads, benefits and human...more

Post-Holiday Gift – ACA Reporting Deadlines Relaxed for 2016

We have been shouting the ACA reporting compliance deadlines from the rooftops for months now. Well, I guess it is a case of the “boy who cried wolf”. At the eleventh hour, the IRS has caved to a slew of complaints,...more

The Affordable Care Act’s Reporting Requirements for Carriers and Employers (Part 23 of 24): Notice 2016-4 Postpones Reporting and...

Under the Affordable Care Act’s reporting requirements that have been the subject of this series, statements to responsible individuals (a/k/a “employees”)—i.e., Forms 1095-B and 1095-C—must be furnished on or before January...more

Provisions in Appropriations Act Affecting Employee Benefit Plans

The $1.8 trillion, 887-page spending bill enacted by Congress this month, the Consolidated Appropriations Act, 2016 (the Appropriations Act), became law on Dec. 18, 2015. Below is a summary of the principal provisions of the...more

Health Care and the ACA: IRS Formalizes Position on Opt-Out Payments

On December 16, 2015, the IRS, the Department of Health and Human Services, and Department of Labor issued Notice 2015-87, which provides guidance on the application of various provisions of the Affordable Care Act (ACA) to...more

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