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’Tis the Season to Answer Employer Shared Responsibility Payment Letters From the IRS

The deadline to respond is nearing for employers that received the first wave of Letter 226J mailings proposing to assess them with Employer Shared Responsibility Payments (ESRPs) for 2015 under Section 4980H of the Internal...more

HRA Access for Spouses and Dependents: A New Wrinkle for Form 1095-C

Imagine that you are filling out Internal Revenue Service Form 1095-Cs for 2015 for an employer that offers employees the opportunity to elect self-only or family coverage under a minimum value group health plan. The plan...more

King v. Burwell: What to Expect From the Supreme Court Argument

On Wednesday, March 4, 2015, the Supreme Court of the United States will hear argument in King v. Burwell, a case involving premium tax credits under the Affordable Care Act (ACA). Among its many provisions, the ACA includes...more

Administration Announces Plan to Postpone Employer Mandate Assessments Until 2015

A Treasury Department official announced late this afternoon that the Obama administration “will provide an additional year” before certain provisions of the Affordable Care Act go into effect....more

The Advantages of Team Work

There are many things I enjoy about practicing employee benefits law at Ogletree Deakins. One of them is having more than 35 other benefits lawyers with whom to brainstorm so that we can serve our clients better and more...more

Regulatory Storm Cloud Brewing On Full-Time Employee Status

Beginning on January 1, 2014, it will be crucial for an employer to know the full-time or part-time status of every employee. That is when the employer mandate becomes effective under Internal Revenue Code § 4980H. Section...more

Helpful Guidance Issued on Employer Mandate Issues

Notice 2012-58 (August 31, 2012) describes a number of safe harbors related to the employer mandate under the Affordable Care Act. In today’s post, I want to focus on the Notice’s safe harbor method for determining the...more

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