News & Analysis as of

FATCA regulations updated but deadlines loom

The US Department of the Treasury and the Internal Revenue Service have released what they refer to as the “last substantial package of regulations” necessary to implement the Foreign Account Tax Compliance Act (FATCA). ...more

"Treasury and IRS Move to Implement FATCA as 2014 Start Date Approaches"

On October 29, 2013, the IRS issued Notice 2013-69 as the next step in implementing far-reaching legislation commonly known as the Foreign Account Tax Compliance Act (FATCA). Congress enacted FATCA in 2010 as part of...more

Health Care Reform Update -- September 9th, 2013

In This Issue: Leading the News; Implementation of the Affordable Care Act; Other HHS and Federal Regulatory Initiatives; Other Congressional and State Initiatives; Other Health Care News; and Hearings and Mark-Ups...more

Employment Law Advisory for August 21, 2013: Health Care Reform: What Employers Need to Know Now

Last year, the United States Supreme Court upheld the Affordable Care Act, the sweeping health care law enacted by Congress and signed into law by President Obama in 2010. Many of the most important provisions of the law...more

Now for Everything Else: What Employers Still Need To Worry About Between Now And 2015

For the past several months (and, in many cases, years), most large employers have been preparing for the consequences of offering (or not offering) their workforce health coverage and complying with the complexities...more

Too Soon for Party Hats: Employers Face Array Of "Underground" Challenges Following The Employer Mandate Delay

Like many, I was initially relieved when I read the July 2, 2013, announcement by the U.S. Treasury Department, effectively providing "large" employers with up to an additional year (to 2015) to comply with the ACA's Employer...more

Employer Responsibility – Will You Pay or Play? Part II - The Variable Hour or Seasonal Employee Problem

Although the employer mandate has been delayed to 2015, employers shouldn’t relax too much because significant planning still needs to be done now. Beginning in 2015 large employers either must offer full-time employees...more

Affordable Care Act Update IRS Issues Guidance on Delay of Employer Shared Responsibility Penalties and Reporting Requirements

On July 2, 2013, the Treasury Department made a surprise announcement that enforcement of the Employer Shared Responsibility Mandate, a provision of the Patient Protection and Affordable Care Act ("PPACA"), would be delayed...more

Health Care Reform Update: Employer Shared Responsibility Provisions Delayed Until 2015; Other Provisions on the Horizon

On July 10, 2013, the IRS issued a formal notice delaying the effective date of the employer shared responsibility provisions under the Patient Protection and Affordable Care Act (“PPACA”) until January 1, 2015 (or later, for...more

Benefits Update, No. 3, August 2013: Healthcare Reform: What Was and Was Not Delayed?

On July 2, 2013, the U.S. Treasury Department delayed enforcement of the employer “play or pay” mandate penalties and reporting requirements one year to 2015, stating that covered employers should still comply with the...more

Treasury Delays FATCA Deadlines by Six Months

On July 12, the Treasury Department issued Notice 2013-43, which provides a revised timeline for the Foreign Account Tax Compliance Act (FATCA). The FATCA withholding and reporting requirements will be delayed six months...more

Health Care Reform Implementation Update - July 23, 2013

With only two weeks before Congress’ August recess and just a little more than two months before October open enrollment begins, Washington is busy sorting through, implementing and, in some cases, fighting the Affordable...more

Treasury and IRS Extend FATCA Deadlines

Notice 2013-43, released on July 12, 2013, announces the Internal Revenue Service’s (the IRS) and the Department of the Treasury’s intent to amend final Treasury regulations implementing the U.S. Foreign Account Tax...more

U.S. Treasury Department Delays Enforcement of Employer Mandate and Reporting Requirements Under PPACA

As seen in many mainstream press reports, the Obama administration announced in early July that (1) the employer mandate and (2) certain reporting requirements under the Patient Protection and Affordable Care Act (PPACA) will...more

Treasury and IRS Extend FATCA Deadlines

Notice 2013-43 (http://www.irs.gov/pub/irs-drop/n-13-43.pdf), released on July 12, 2013, announces the Internal Revenue Service's (the "IRS") and the Department of the Treasury's intent to amend final Treasury regulations...more

ACA Responsibility Payments, Mandatory Employer and Insurer Requirements Delayed

Those of you just arriving on the planet may have heard a little something about the Affordable Care Act and the fact that it has a lot of folks worried about just how it will all work....more

Extension of FATCA Withholding Start Date and Grandfathering End Date

On July 12, Treasury and the IRS announced that they intend to amend final Treasury regulations implementing the U.S. Foreign Account Tax Compliance Act (FATCA) to provide for a six-month extension to the start of FATCA...more

Legal Alert: New Extended FATCA Implementation Dates

On July 12, 2013, the IRS, in Notice 2013-43, and the Department of the Treasury in a Press Release of the same date, extended the implementation dates by six months for many of the withholding and account due diligence...more

Department of Labor Sets October 1, 2013, Deadline For Employers To Give Employees Notice Of Exchange Available Under the...

On May 8, 2013, the Department of Labor (“DOL”) issued guidance to employers for giving notice to employees as required by Fair Labor Standards Act (“FLSA”) § 18b. Section 1512 of the Patient Protection and Affordable Care...more

The Affordable Care Act – Consider Yourself on Notice

Under the Affordable Care Act, employers subject to the Fair Labor Standards Act must provide a “Notice of Coverage Options” to each employee. The purpose of this Notice is to inform employees that they may obtain health...more

It’s Official: IRS Issues Guidance Affirming One-Year Delay in the Affordable Care Act Employer Mandate and Related Reporting...

On July 9, less than a week after the Obama administration announced a one-year delay in the enforcement of the employer shared responsibility (aka “pay-or-play”) rules,1 the IRS has issued guidance making the move official....more

Legal Alert: Guidance Released On Delay Of "Pay Or Play" Penalties Under ACA

The Obama Administration has released formal guidance on the delay of the Affordable Care Act's (the "ACA") employer mandate and certain reporting requirements. ...more

Employers Face Compliance Options In Lights Of Delayed Implementation Of Pay Or Pay Mandate Under The ACA, But Other ACA...

On July 2, 2013, the Treasury Department’s announced that enforcement of the "Pay or Play" mandate under the ACA will be delayed until January 1, 2015. This announcement was followed by a brief notice from the IRS which...more

Legal Alert: IRS Issues Transition Relief Guidance on PPACA Reporting and Employer Penalty

On July 9, the Internal Revenue Service (IRS) released Notice 2013-45 (the Notice), granting transition relief from the “Employer Shared Responsibility” provisions and certain health plan reporting requirements under the...more

IRS Issues Transition Relief On The One-Year Delay In PPACA’s Information Reporting And Employer Shared Responsibility Rules

Late on July 9, 2013, the IRS issued Notice 2013-45 which provides some additional information regarding the Department of Treasury’s recently announced delay in the information reporting and employer shared responsibility...more

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