The Chartwell Chronicles: Dependency
The Commonwealth of Pennsylvania changed its tax treatment of assistance that employers provide for dependent care services – including dependent care flexible spending accounts. Retroactive to January 1, 2023, Pennsylvania...more
On April 28, 2023, the Internal Revenue Service’s (IRS) Office of Chief Counsel released guidance reiterating claims substantiation rules for health flexible spending arrangements (health FSAs) under Internal Revenue Code...more
A recent memorandum from the IRS Office of Chief Counsel serves as a helpful reminder to check in on cafeteria plan administration and ensure all processes—including claims substantiation for medical expenses and dependent...more
Following up on guidance issued in February the IRS has issued a new notice on the temporary carryover rules for dependent care flexible spending accounts. The 2021 Consolidated Appropriations Act (CAA) provides that, for...more
On May 10, 2021, the IRS issued Notice 2021-26, which provides guidance regarding the taxation of dependent care assistance benefits provided through a Code Section 125 cafeteria plan, available in tax years ending in 2021...more
The Taxpayer Certainty and Disaster Tax Relief Act of 2020 – part of the Consolidated Appropriations Act ("CAA") – allows an employer to amend its cafeteria plan to allow either an unlimited carryover or a 12-month grace...more
As the IRS continues to churn out guidance on various forms of COVID-19 relief, this week is no exception with the release of Notice 2021-26. This Notice clarifies two key points relating to the tax treatment of dependent...more
Yesterday the IRS released Notice 2021-26, which clarifies that if eligible dependent care benefits would have been excluded from income if used during either the prior tax year (2020 or 2021), these benefits remain...more
The American Rescue Plan Act of 2021 (“ARPA”) includes a valuable benefit for an employee who has lost (or loses) healthcare coverage due to an involuntary termination or reduction in hours — up to 6 months of free COBRA...more
The American Rescue Plan Act of 2021 (ARPA) requires fully subsidized COBRA premium payments for assistance eligible individuals beginning as early as April 1, 2021, and ending as late as September 30, 2021 (the Subsidy...more
The American Rescue Plan Act of 2021 ("ARPA") includes a 100% COBRA subsidy for "assistance eligible individuals" during the six-month period of April 1, 2021 through September 30, 2021. Following is a summary of the COBRA...more
Earlier this month, the American Rescue Plan Act of 2021 (ARPA) became the latest COVID relief package passed by the federal government. ARPA, just like the many COVID relief packages that came before it, contains a number...more
President Biden signed The American Rescue Plan Act of 2021 (“ARPA”) into law on March 11, 2021, adding new employee benefits relief and providing extensions of prior COVID-19 relief. In our prior Alert[1] we discussed ARPA’s...more
On March 11, 2021, President Biden signed into law the American Rescue Plan Act of 2021 (“ARPA”) which is another coronavirus stimulus package aimed at speeding up the United States’ recovery from the economic and health...more
The COVID-19 pandemic and large-scale “stay at home” orders left many employers facing questions relating to the elections employees made with respect to their dependent care benefit accounts. Since then, a number of major...more
The just-signed American Rescue Plan Act (ARPA) contains several provisions to help multiemployer and single employer plans fund retiree benefits. Two less-noticed provisions greatly increase the child care tax credit and...more
The American Rescue Plan Act of 2021 (the “Act”) was signed into law on March 11, 2021. As well as providing extended unemployment, the Act provides for subsidized COBRA, an increase in the amount of dependent care...more
The American Rescue Plan Act of 2021 (“ARPA”), which was signed into law on March 11, 2021, includes a number of provisions relating to health and welfare plans that will be beneficial to many Americans. In addition, ARPA...more
On March 11, 2021, President Biden signed the American Rescue Plan Act (ARPA). This Client Advisory focuses on the new mandatory and voluntary provisions for employee benefit plans and raises questions about the impact of the...more
For employers with group health plans, COBRA obligations under President Biden’s premiere $1.9 trillion stimulus legislation, the American Rescue Plan Act of 2021 (the “Rescue Plan”) are an early priority. ...more
The American Rescue Plan Act of 2021 includes a COBRA premium subsidy and increases the dependent care flexible spending account (DCFSA) limits. While the availability of the COBRA premium subsidy is a requirement, the...more
On March 11, 2021, President Biden signed into law the American Rescue Plan Act of 2021 (the “Act”). As part of the almost $2 trillion in relief, the Act contains provisions creating a temporary subsidy for premium payments...more
President Biden has signed into law the American Rescue Plan Act of 2021. The act contains a number of provisions affecting employee benefit plans. A description of some of these changes follows: Beginning April 1, 2021, and...more
The IRS recently issued Notice 2021-15 to provide guidance on certain provisions of the Consolidated Appropriations Act of 2020 (the "CAA") affecting the administration of flexible spending accounts ("FSAs"). The CAA changes...more
The American Rescue Plan Act of 2021 (ARPA) is the latest federal COVID-19 relief bill, which the President signed into law March 11, 2021. ARPA includes new COBRA continuation coverage election, notice, and subsidy...more