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

The Patient Protection and Affordable Care Act (PPAC), also known as Obamacare, is a United States federal statute passed in March of 2010. The Act creates a nationwide insurance system and provides federal... more +
The Patient Protection and Affordable Care Act (PPAC), also known as Obamacare, is a United States federal statute passed in March of 2010. The Act creates a nationwide insurance system and provides federal subsidies to reduce the number of uninsured citizens. less -
News & Analysis as of

Health Care Alert: ACA Health Insurance Subsidies Called into Question by DC Circuit

Yesterday, a divided three judge panel of the United States Court of Appeals for the DC Circuit struck down the IRS regulation allowing federal premium subsidies for individuals buying health insurance at...more

Recent Tax Developments

The following is a summary of the most important tax developments that have occurred in the past several months that may affect you, your family, your investments, and your livelihood. Please call us for more information...more

Dueling Districts on Major Challenge to Federal Health Reform

Are Employers in States Without Exchanges Subject to Penalties? In two highly technical and comprehensive rulings out July 22, 2014, two federal districts came to opposite conclusions on a key remaining challenge to...more

A Tale of Two Circuits: D.C. Circuit, Fourth Circuit Split on ACA Subsidies

It was the best of times for ACA subsidies, it was the worst of times for ACA subsidies. On Tuesday, the Court of Appeals for the D.C. Circuit (“D.C. Circuit”) and the Court of Appeals for the Fourth Circuit (“Fourth...more

Health Law Blog: Court Strikes Down Tax Credit Provision for Low Income Americans Participating Through Federal and Federal/State...

Yesterday, the United States Court of Appeals for the District of Columbia ruled the IRS’ interpretation of a key ACA provision is invalid. Specifically, the court found that the IRS did not have the authority to interpret...more

Health Care Reform Implementation Update - July 2014

Last week the Senate debated a bill to reverse the Supreme Court’s contraception mandate decision, a group of House Republicans introduced a bill to replace Affordable Care Act (ACA) cuts to the Medicare home health benefit...more

The Affordable Care Act—Countdown to Compliance for Employers, Week 24: Can Offers of Group Health Plan Coverage Under Code...

The Employer Shared Responsibility provisions of the Affordable Care Act (“ACA”) generally require “applicable large employers” (i.e., employers who employed at least 50 full-time and full-time equivalent employees on...more

Affordable Care Act Update: Final Regulations Assist Employers With Identifying Full-Time Employees and Reporting Requirements

Earlier this year, the IRS issued final regulations implementing the employer shared responsibility provisions (the “Pay-or-Play Mandate”) of the Patient Protection and Affordable Care Act (“PPACA”). We issued a Client...more

Key Questions Left in the Wake of the Supreme Court's Hobby Lobby Decision

On June 30, 2014, the U.S. Supreme Court held in Burwell v. Hobby Lobby Stores, Inc. et al., that the Affordable Care Act's "contraceptive mandate", as applied to "closely held corporations", violates the Religious Freedom...more

Monthly Benefits Update

In Burwell v. Hobby Lobby, the Supreme Court held that regulations under the Affordable Care Act that require employer group health plans to provide contraceptive coverage violate the Religious Freedom Restoration Act (RFRA)....more

The IRS Says (Again) That Certain Employer Payment Plans Won’t Fly

The IRS recently issued two new Q&As to underscore that arrangements allowing employers to reimburse employees on a pre-tax basis for premiums used to purchase individual health coverage, either inside or outside of a public...more

The Affordable Care Act—Countdown to Compliance for Employers, Week 26: Fitting a Round Peg (the Public Health Service Act 90-day...

The Departments of the Treasury/IRS, Labor and Health and Human Services (the “Departments”) recently issued a final regulation under the 90-day waiting period limitation, which is included among the Affordable Care Act’s...more

The Affordable Care Act—Countdown to Compliance for Employers, Week 28: The Logic, Calculus, and Limits of “Skinny” Plans

It was just over a year ago that the Wall Street Journal published an article entitled, “Employers Eye Bare-Bones Health Plans Under New Law,” which highlighted a compliance strategy to minimize employer exposure for...more

HEAL Advisory: Challenges to IRS Regulations Allowing Subsidies in Federally-Established Exchanges Under the ACA: Federal Court...

Challenges to federal health reform implementation continue to make their way through the federal courts, with court rulings expected shortly. Employers are especially advised to monitor challenges to the federal regulations...more

IRS Issues Guidance Effectively Prohibiting Employers From Reimbursing Employees For Individual Health Insurance Premiums

The IRS’ reasoning is that such reimbursement arrangements, often referred to as “employer payment plans” are “group health plans.” All group health plans must meet the Affordable Care Act’s “market reform” requirements, such...more

Health care reform reporting requirements: Final rules

The Patient Protection and Affordable Care Act (PPACA) contains requirements for both individuals and employers related to health care coverage. In order to assure compliance with certain of these requirements, PPACA requires...more

Religious Institutions Update - Lex Est Sanctio Sancta

"Church plans" are pension plans (including defined benefit or defined contribution plans) exempt (without an irrevocable election) from many of the legal requirements of the Employee Retirement Income Security Act (ERISA)...more

Labor Pains: The $2 Million Part-Time Employee

One of your employees (we’ll call him “Don”) cannot enroll in your health insurance plan because you classify him as “part-time” (one who works less than 30 hours a week). This forces Don to get health insurance through a...more

Monthly Benefits Update

Health & Welfare Plans - July 1 Deadline to Begin Measuring Employee Hours for ACA Employer Mandate/“Pay or Play” - As we have discussed in many previous alerts, the Affordable Care Act’s employer shared...more

IRS Disallows Shifting Employee Health Coverage Burden to Exchanges

Certain employers hoped that they had discovered a way to "have their cake and eat it too". In response to the looming employer mandate for employers with 50 or more employees – the requirement to offer full - time employees...more

IRS Says It Will Penalize Employers Dumping Employees into Obamacare

Before the ink on the Affordable Care Act was dry, prudent employers were analyzing the law to identify ways to save money and avoid many of the punitive aspects of the law....more

The Affordable Care Act—Countdown to Compliance for Employers, Week 31: ERISA Section 510 and Limiting Employee Hours

In last week’s post, we examined the appropriateness of capping the annual hours of new “variable hour employees” as a way to limit exposure under the Affordable Care Act’s employer shared responsibility rules. (These rules...more

Survey of Current Benefits Issues

In This Presentation: - Affordable Care Act - Affordable Care Act: Fees and Taxes 2015 – Employer Shared Responsibility Fee - Forms for Reporting Fees - Retirement Plan Errors - Overview - Retirement Plan...more

What Does PPACA Stand For? Punitive Penalties Are Clearly Authorized

A recently posted IRS Q&A raises the specter of serious penalties for non-compliance with the Affordable Care Act. The context of the question relates to the consequences to employers that do not establish a health insurance...more

Whose Risk Is It Anyway? New Revenue Ruling Provides Guidance for Employee Benefits Captives

On May 8, the IRS issued Rev. Rul. 2014-15, 2014-22 I.R.B. 1, which provides guidance in the rapidly expanding area of insuring or reinsuring employee benefits with captives. ...more

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