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The IRS has issued its first ACA penalty letters for tax year 2021. While employers have been forewarned, many may not be fully armed to respond in a timely and compliant manner. The IRS is making good on its promise, and...more
If you need help determining whether you are an “applicable large employer” subject to these rules or estimating the extent of potential penalty exposure, our Employer Shared Responsibility Penalty Checklist for Employers may...more
Employers, take note: 2023 brings heftier IRS penalties for failure to comply with the ACA’s Employer Mandate. Under the ACA’s Employer Mandate, ALEs, or employers with 50 or more full-time and full-time equivalent...more
On October 11, 2022, the US Department of Treasury (Treasury) and the Internal Revenue Service (IRS) issued final regulations to modify how affordability under the Affordable Care Act (ACA) is determined for an offer of...more
As we discussed in a prior article, it is now more important than ever for employers to ensure they fully and accurately complete IRS Forms 1094-C and 1095-C — forms required to be filed and/or furnished to employees under...more
On November 5, 2021, the federal Department of Labor’s Occupational Safety and Health Administration (OSHA) published its "COVID-19 Vaccination and Testing, Emergency Temporary Standard" (ETS) for employers with 100 or more...more
On November 4, 2021, the Occupational Safety and Health Administration (OSHA) released its Emergency Temporary Standard (ETS) applicable to all private employers in the United States with 100 or more employees. ...more
On November 4, 2021, as President Biden ordered, the Occupational Safety and Health Administration (OSHA) released its emergency temporary standard (ETS) concerning vaccination requirements. As predicted, the ETS requires...more
On November 4, 2021, the Occupational Safety and Health Administration (OSHA) revealed its Emergency Temporary Standard (ETS) on COVID-19 Vaccination and Testing, which has been published in the Federal Register and is...more
On October 12, 2021, the United States Occupational Safety and Health Administration (OSHA) sent its highly anticipated emergency temporary standard (ETS), also known as the COVID-19 “vax-or-test rule,” to the White House for...more
Executive Order 14042 (Ensuring Adequate COVID Safety Protocols for Federal Contractors), the resulting guidance and the recent array of class deviation contract clauses create interesting and novel federal contract...more
On August 3, 2021, New York City Mayor Bill de Blasio announced the “Key to NYC” program (“Key to NYC” or the “Program”), which implemented new mandatory COVID-19 vaccination requirements for employees and patrons of certain...more
A recently released redacted report from the Treasury Inspector General for Tax Administration (TIGTA) offers some helpful insights for employers who may be assessed shared responsibility payments because the IRS thinks they...more
Since 2015, employers and health insurers have been required to report health plan coverage information to the IRS and to individuals. Why? The information is necessary in order for the IRS to administer certain portions of...more
You’ve been at this Affordable Care Act reporting for years and are cruising on autopilot, right? Regardless of your confidence level, all employers need to note the extended due date for furnishing Form 1095-C to individuals...more
Once again, the IRS has extended the deadline for furnishing Forms 1095-B and 1095-C to individuals. Reporting penalties will not apply to those who meet the applicable deadlines and complete the forms in good faith....more
With only 30-days to respond, employers should be watching their mail for Affordable Care Act (ACA) employer mandate penalty letters (IRS Letter 226J), coming before the end of 2017. Recent updates to the “Questions and...more
The Affordable Care Act or ACA (a/k/a “Obamacare”) is not dead, yet. Employers are starting to receive letters from the IRS notifying them that they owe assessable payments (“penalties”) under the employer shared...more
Businesses should be aware that the IRS has initiated enforcement of the employer shared responsibility provisions of the Affordable Care Act (the "Act") – which could mean your business is about to receive (if it hasn’t...more
The IRS has finally started to enforce the employer shared responsibility requirement (the “employer mandate”) in the Affordable Care Act, and is mailing notices now to employers who may owe a penalty for 2015. Because of...more
Recently, the Internal Revenue Service (IRS) indicated that it would begin enforcing the Affordable Care Act (ACA) Employer Shared Responsibility provisions (commonly known as the "Employer Mandate"). Last week, the IRS...more
Within the past few weeks, IRS officials have informally indicated that the IRS would begin assessing tax penalties under the Affordable Care Act’s (ACA) employer shared responsibility. The IRS has now updated its Questions...more
The IRS has taken actions indicating that employer mandate penalties under the ACA are about to be enforced. The recently updated Questions and Answers on Employer Shared Responsibility Provisions Under the Affordable Care...more
You may recall that President Trump signed an executive order on the day of his inauguration directing all agencies to minimize the economic burden of the Affordable Care Act (ACA) pending its repeal. You may recall also that...more
The U.S. Senate Republicans on July 13, 2017, released an updated discussion draft of the Better Care Reconciliation Act of 2017 (BCRA), its bill to repeal and replace the Affordable Care Act (ACA). As we have outlined in a...more