With the 2016 employer mandate tax assessment letters hitting employer desks this week, it seems like a good time to summarize our experience with the 2015 ESRP process. ...more
There’s a comically profound scene in the second “Madagascar” movie. Penguin (management) and monkey (union) committees are negotiating a labor contract. After the monkeys seem to have secured what they want, they add a...more
Entering a football stadium many years ago, your nimble correspondent encountered unarmed security contractors wearing uniforms featuring the company logo – a big, red bull’s-eye – on the front of the baseball cap and on the...more
On November 17, the IRS published the Form that Applicable Large Employers must use to respond to IRS letters regarding proposed assessment of 2015 employer mandate taxes. Form 14764 is a paper, mail-in “ESRP Response” that...more
Just days ago, “Questions and Answers on Employer Shared Responsibility Provisions Under the Affordable Care Act,” No. 57 read as follows:
Does the IRS expect to publish more information about the employer shared...more
That’s the title of a web page that employers may find helpful upon receipt of an IRS communication asserting liability for employer mandate taxes under Code § 4980H. It should have an official notice (“CP”) or letter...more
Does the IRS expect to publish more information about the employer shared responsibility payment procedures?
Yes. The IRS expects to publish guidance of general applicability describing the employer shared responsibility...more
We don’t blame you for hearing that whenever someone warns of employer mandate taxes coming your way. Nevertheless, we’re donning the chicken suit once again to keep you aware. This time, we’ll keep it short and mainly...more
ACA “repeal” proposals at this point seem like zombie extras – walking dead, and none of them purports to repeal employer mandate taxes that accrued in 2015. Collection is coming; only the timing is in question.
ACV 2.0 is...more
The “Discussion Draft” released June 22, 2017 by the Senate Budget Committee carries the House Bill number (H.R. 1628) of the American Health Care Act, and kills taxes like the House bill, but there are major differences,...more
Maxwell Smart, aka “Agent 86” in the 1960’s TV series Get Smart, claimed to have survived “fiendish” water torture – 300 gallons at the rate of one drop a minute. When disbelieved, he asked, “Would you believe a quart?” The...more
During the week reviewed, no new bill was introduced which, if passed, would repeal or replace the Affordable Care Act, and little else happened at the three main ACA enforcement agencies – DOL, HHS and IRS.
Department...more
Since late December, 2016, many Applicable Large Employer Members have received IRS Letter 5699 from a Tax Compliance Officer at an address in Florence, Kentucky. The “Dear Taxpayer” letter is headed: “Request for Employer...more
As previously reported, § 2001 of the 2017 budget bill required all ACA repeal/replace bills to be filed and reported from assigned committees by Friday, January 27, 2017. That didn’t happen. Since our last posting, the...more
We didn’t take ten weeks off because there was nothing to talk about. Rather, we concluded around Labor Day that anything useful to be said about ACA compliance, pre-election, would be interpreted as political advocacy, so...more
If your EIN will have 250 or more full-time employees in 2016 (counting each person who was full-time in any month) you’ll need next year to file your 2016 ACA Information Returns – Forms 1094-B and 1095-B or Forms 1094-C and...more
In the ACA realm, change is the only constant, so don’t take this to the bank. We’re telling you what we see for the first time, on a first reading of the draft 2016 Forms and Instructions that the IRS has released since...more
All of us of a certain age remember the Bugs Bunny cartoon in which Bugs and Daffy confused dimwit Elmer Fudd as to the current hunting season – i.e., wabbit (Bugs) or duck (Daffy) – ending with the proclamation of baseball...more
Ten days before the deadline for electronic filing of 2015 Forms 1094-C and 1095-C, many employers are discovering that they contracted for less than all the needed services. Here’s what we’re seeing all too...more
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
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
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
Lawyers, politicians, economists, climate scientists, fad diet peddlers . . . we all know that it’s child’s play to persuade people of what they want to believe. Perhaps that explains the persistence of so many...more
On December 28, 2105, the IRS released its Notice 2016-4, granting much needed time for employers and their filing services to catch up to Affordable Care Act Information Return (AIR) Program developments. ...more
Was the title of a 1970 soul hit for the Chairmen of the Board. Though your love for ACA information reporting is unlikely to grow as a result, you may need a little more time to get it done. This article responds to multiple...more