Watching from afar the Scouts attempting to earn their orienteering merit badges, we could see it on the boys’ faces.  They were lost; they were scared.  They should have reached their destination an hour ago.  Soon, these woods would be dark.   The compass holder, the map marker and the step counter resumed their running argument. We wondered whether to intervene.  Then, the class clown smiled . . . and pointed . . . at a rusted, single-wide trailer they had seen before, very near their departure point.  In five hours, they had come full circle.  They had done a lot wrong and were glad just to know how to get back to our campfire. Success could wait.

And so it is with ACA repeal.  A better-planned, better-executed effort may be mounted, but probably not soon.  Between now and then, 2015 employer mandate taxes will be assessed and collected, and perhaps 2016 taxes, too.  OSHA will investigate the retaliation complaints of employees discharged after triggering those tax assessments by seeking ACA Marketplace subsidies.  Form 1094-C / Form 1095-C reporting penalties will be imposed.  Group health plans will be audited for ACA compliance.  Temp staffing and employee leasing arrangements will be disrupted by those developments.  Consequently, we now return you to our regularly scheduled program.  If ACA compliance has been sidelined or forgotten in your organization, now would be a good time to tune-in.

IRS CIRCULAR 230 DISCLOSURE

Thank you for your interest in our information on the current status of Affordable Care Act and its implementation. While we are happy to provide you our best information and analysis of the regulations promulgated by the Internal Revenue Service, please be advised that the contents and conclusions contained in this article and any email communication are introductory and educational in nature and do not express a formal, enforceable opinion. Nothing contained in this article and any email communication is intended to be used, or relied upon by any taxpayer for the purpose of avoiding taxation and penalties that may be imposed under the Internal Revenue Code. Any statement contained in this article and any email communication relating to any federal tax issue may not be used by any person to support the promotion, marketing of, or used to recommend any transaction for the purpose of avoiding taxation or penalties.