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

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
News & Analysis as of

Cadillac Tax: A Levy in Limbo

The future of the Cadillac tax, a key cost-control mechanism and federal revenue source enacted as part of the Patient Protection and Affordable Care Act (ACA), is unclear. Though initially set to take effect in 2018,...more

A&B Healthcare Week in Review

I. REGULATIONS, NOTICES, & GUIDANCE - On April 21, 2016, CMS issued a proposed rule entitled, “Medicare Program: FY 2017 Hospice Wage Index and Payment Rate Update and Hospice Quality Reporting Requirements.” This...more

New ACA, et. al. FAQs Cover Items From “Top” to “Bottom”

On April 20, the “Big Three” agencies (DOL, Treasury/IRS, and HHS) released another set of FAQs (the 31st, for those of you counting at home). Consistent with earlier FAQs, the new FAQs cover a broad range of items under the...more

So You’ve Filed Your 1095-C…Now What?

As companies complete their Section 6055 and 6056 reporting under the Affordable Care Act (ACA), now it’s time to be on the lookout for notices regarding ACA penalties....more

Three Key Takeaways from NAFOA's 34th Annual Conference

The Native American Finance Officers Association (NAFOA) held its 34th annual conference on April 17-20, 2016, at the Gila River Indian Community's Sheraton Wild Horse Pass Resort in Phoenix. NAFOA is a national non-profit...more

A&B Healthcare Week in Review

I. REGULATIONS, NOTICES, & GUIDANCE - On April 15, 2016, the Food and Drug Administration (FDA) issued a proposed rule entitled, “Applications for Approval and Combinations of Active Ingredients Under Consideration for...more

Late Or Incorrect Forms 1095-C: The IRS Provides Relief, But Only For Employers Acting In Good Faith To Comply Or Who Missed The...

Many employers struggled to furnish correct Forms 1095-C to employees by the March 31, 2016 deadline. Section 6721(a)(2) of the Internal Revenue Code provides penalties for failure to furnish Forms 1095-C to individuals by...more

Reminder to Charitable Hospitals: Final Section 501(r) Regulations Effective

Section 501(r) of the Internal Revenue Code was added by the Affordable Care Act (ACA) and imposes significant new requirements on charitable hospitals. At a very summary level, this section requires charitable hospitals...more

Affordable Care Act Traps For The Unwary (And Not) Employer: Tips To Comply And What To Avoid

Hopefully, most employers that are applicable large employers (“ALEs”), i.e., employers that averaged 50 or more full-time employees (including full-time equivalents) in the prior calendar year, now have their game plan in...more

So I Made This Little 1095-C Mistake. Big Deal?

The 2015 Instructions for Forms 1094-C and 1095-C tell Applicable Large Employers how to furnish and file corrections to incorrectly filed Forms 1095-C. ...more

Recent Government-Issued FAQs Clarify ACA Employer Mandate, Market Reforms

Notice 2015-87 (the Notice) provides recent government guidance on the Affordable Care Act (ACA) employer mandate and market reforms. The Notice contains 26 frequently asked questions (FAQs) from the Internal Revenue Service...more

The ERISA Litigation Newsletter - March 2016

Editor’s Overview - This month we review the U.S. Supreme Court’s decision in Montanile v. Board of Trustees of National Elevator Industries Health Benefit Plan where the Supreme Court considered the scope of...more

IRS Provides Guidance on Suspension of Medical Device Excise Tax

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

Double Check Your Work: IRS to Step Up Section 501(r) Hospital Examinations

Tax-exempt hospitals will likely be targets of stepped up compliance checks and examinations in the coming months. Referencing the in-depth review of tax-exempt hospitals required by the Affordable Care Act (ACA), Donna...more

ACA Reporting: IRS Deadline of March 31 Looms for Applicable Large Employers

Applicable large employers have new reporting requirements under the Affordable Care Act (ACA). Whether an employer is an applicable large employer is determined each calendar year by looking at the employer's workforce...more

Heffalumps, Woozles and Limited Non-Assessment Periods: Very Confusel

So, you were a 2015 Applicable Large Employer. You waited too late to outsource your generation, furnishing and filing of 2015 Forms 1095-C. Fortunately, you believe, you are permitted to file on paper, by May 31, 2016,...more

New ACA Guidance Warrants Another "Checkup" of Employer Health Plans

On December 16, 2015, the IRS issued Notice 2015-87 (the "Notice"), which provides "question-and-answer" guidance regarding how various Affordable Care Act (the "ACA") provisions apply to employer-provided group health plans....more

When It Comes To The ACA, Change Is The Only Constant: Five Recent ACA Changes You Need to Know About

While many of us were busy celebrating the holidays, Congress and the IRS were hard at work creating and promulgating revisions to the Affordable Care Act (ACA). Here’s what you need to know about the most recent changes....more

EEOC Loses Another Wellness Case, Part 2 – Beware the ACA Penalties

In my last blog post, I discussed a recent loss by the EEOC in its efforts to limit the ability of employers to require employees to complete health risk assessments (HRAs) or biometric screenings in order to enroll in the...more

Code § 4980H: The Tax The Beatles Missed

The Tax Man, it turns out, also may assess you for failing to offer substantially all your full-time employees and their dependents affordable, qualifying group health coverage during 2015. We’re swamped with employer...more

ACA Reporting Update – The Final Stretch

After months of preparation and multiple iterations of (sometimes conflicting) IRS guidance, health coverage providers and applicable large employers are nearing the end of the 2015 reporting season under the Affordable Care...more

Affordable Care Act Reporting is Here (But May be a Little Late…)

The Affordable Care Act requires “applicable large employers” (generally, employers with 50 or more full-time employees and full-time employee equivalents) to provide individual statements to their full-time employees and to...more

Employee Benefits Developments February 2016

IRS Issues Guidance Regarding Application of ACA Fee to Expatriate Health Plans. Section 9010 of the Affordable Care Act (ACA) imposes an annual fee on covered entities engaged in the business of providing health insurance...more

Affordable Care Act Compliance Update for 2016

Affordable Care Act (ACA) reforms have become effective incrementally over the last six years. In 2016, most of the ACA changes are applicable. Employers that sponsor group health plans should ensure that they are in...more

Student Health Plans and ACA Compliance: New Relief for Educational Institutions

Educational institutions face unique issues when complying with the requirements of the Affordable Care Act (ACA). One such issue relates to the administration of student health insurance plans. On February 5, 2016, three...more

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