The Patient Protection and Affordable Care Act of 2010, together with the Health Care and Education Reconciliation Act of 2010 (collectively, the “Affordable Care Act”), provide that, effective for plan years beginning on or after September 23, 2010, a plan or issuer that makes available dependent coverage of children must make such coverage available to children until the attainment of 26 years of age (the “Coverage Requirement”). In a sister provision effective upon enactment of the Affordable Care Act (March 31, 2010), the Affordable Care Act amends Section 105(b) of the Internal Revenue Code (the “Code”) to provide that medical reimbursements made to an employee with respect to any child of the taxpayer are not taxable through the end of the taxable year in which the child turns 26 (the “Tax Provision”).1