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Internal Revenue Service Look-Back Measurement Period

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
Jones Day

U.S. Supreme Court Rules that Bankruptcy Code Provides Only Limited Abrogation of Sovereign Immunity to Avoidance Actions

Jones Day on

Bankruptcy trustees and chapter 11 debtors-in-possession ("DIPs") frequently seek to avoid fraudulent transfers and obligations under section 544(b) of the Bankruptcy Code and state fraudulent transfer or other applicable...more

Kelley Drye & Warren LLP

Ten Years Gone – Delaware Bankruptcy Judge Rejects Effort to Extend Lookback Period for Avoidance of Pre-Bankruptcy Transfers

A recent decision by Delaware Bankruptcy Judge John Dorsey will limit the ability of bankruptcy trustees to expand the lookback period for avoiding pre-bankruptcy transfers beyond the four years provided under most state law...more

Jones Day

Another Court Adopts Majority View in Approving Bankruptcy Trustee's Use of Tax Code Look-Back Period in Avoidance Actions

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The ability of a bankruptcy trustee or chapter 11 debtor-in-possession ("DIP") to avoid fraudulent transfers is an important tool promoting the bankruptcy policies of equality of distribution among creditors and maximizing...more

Kramer Levin Naftalis & Frankel LLP

Bankruptcy Court Permits Chapter 7 Trustee to Utilize IRS’ Look-Back Period in Seeking to Avoid Fraudulent Transfers

In its recent decision in Mitchell v. Zagaroli, Adv. Pro. No. 20-05000, 2020 WL 6495156 (Bankr. W.D.N.C. Nov. 3, 2020), the Bankruptcy Court for the Western District of North Carolina held that the Chapter 7 trustee could...more

Miles & Stockbridge P.C.

Bankruptcy Court Within Fourth Circuit Permits Fraudulent Conveyance Claims to Move Forward Under IRS 10-Year Reach Back Period

Miles & Stockbridge P.C. on

A recent opinion by the United States Bankruptcy Court for the Western District of North Carolina kept alive a bankruptcy trustee’s fraudulent conveyance claims based on, in part, the Internal Revenue Code (“IRC”) 10-year...more

Mintz - Employment, Labor & Benefits...

Staffing Firms, Educational Organizations, and Breaks-in-Service under the Affordable Care Act Employer Shared Responsibility...

In Q&A format, recently issued Notice 2015-87 addresses a number of pressing issues that have arisen under the Affordable Care Act (ACA), including that law’s employer shared responsibility rules, information reporting...more

Balch & Bingham LLP

ACA Myths That Just Won’t Die

Balch & Bingham LLP on

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

King & Spalding

Does Your Cafeteria Plan Need to Be Amended Before Year-End?

King & Spalding on

As background, before 2014, an employee’s election to enroll in his or her employer’s health plan pursuant to a cafeteria plan was irrevocable for the entire plan year, unless the employee incurred an event that affected his...more

Mintz - Employment, Labor & Benefits...

The Affordable Care Act’s Reporting Requirements for Carriers and Employers (Part 19 of 24): Terminations, Changes in Status and...

Last week we examined the reporting challenges associated with employee terminations, changes in status, and breaks in service under the monthly measurement method. As we explained, “[t]he final regulations under Code § 4980H...more

Foley & Lardner LLP

Don’t Forget to Amend Cafeteria Plan for New Permitted Election Change Events

Foley & Lardner LLP on

In 2014, the Internal Revenue Service (IRS) expanded the events that would allow employees to drop their health plan coverage under their employer’s cafeteria plan. As a reminder, the general rule is that once an employee...more

Mintz - Employment, Labor & Benefits...

The Affordable Care Act’s Reporting Requirements for Carriers and Employers (Part 9 of 24): Unraveling the Mystery of Indicator...

The Affordable Care Act’s reporting rules—which are set out in Internal Revenue Code §§ 6055 and 6056—solicit the information needed by the Internal Revenue Service to enforce the individual and employer shared responsibility...more

Robinson & Cole LLP

Continued Disagreement: Use of Federal Debt Collection Laws to Expand Fraudulent Transfer Look-Back Periods

Robinson & Cole LLP on

In Ebner v. Kaiser (In re Kaiser), the U.S. Bankruptcy Court for the Northern District of Illinois allowed a bankruptcy trustee to employ the 10-year look-back period, available to the Internal Revenue Service (IRS) under the...more

Winstead PC

Finding Liberation in the Big Picture of the Employer Shared Responsibility Tax

Winstead PC on

Introduction - So much energy has been spent on what the final regulations on the employer shared responsibility tax and the related final reporting regulations (the ‘‘ESRR’’) say, that some of the most significant...more

Littler

ACA Outlook: What Will 2015 Hold for the Affordable Care Act and Employers?

Littler on

For many employers, the effective date of the Affordable Care Act's "play-or-pay" mandate is only weeks away. The impending deadline comes amid questions about the future—and perhaps viability—of the law itself. Entering...more

King & Spalding

Determining Full-Time Employee Status for ACA: IRS Issues Guidance for Changes in Measurement or Methods

King & Spalding on

The employer shared responsibility provisions (commonly referred to as the "pay-or-play" mandate) of the Affordable Care Act ("ACA") impose penalties on applicable large employers that fail to offer qualifying health coverage...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

New ACA Guidance Permits Employer-Initiated Measurement Period Changes

The Internal Revenue Service (IRS) recently released Affordable Care Act (ACA) guidance addressing how to determine full-time status when an employee’s measurement period changes. The guidance, IRS Notice 2014-49, introduces...more

Eversheds Sutherland (US) LLP

Proposed Approach for Applying the “Look-Back” Method When the Section 4980H Measurement Period Changes

The Internal Revenue Service (IRS) recently issued Notice 2014-49 which describes a proposed approach for determining an employee’s full-time or part-time status for purposes of the employer shared responsibility rules under...more

Ballard Spahr LLP

Health Plan ID Requirements and Other End-of-Year Considerations

Ballard Spahr LLP on

Employers and other health plan sponsors may be focused on preparing for the commencement of the employer mandate under the Affordable Care Act on January 1, 2015, but a number of other deadlines and developments are emerging...more

Franczek P.C.

Monthly Benefits Update - September 2014

Franczek P.C. on

IRS Issues Guidance on How to Deal With a Change to an Employee’s Measurement Period Under ACA Employer Mandate - The Internal Revenue Service (IRS) issued Notice 2014-49, which proposes an approach for dealing with...more

Mintz - Employment, Labor & Benefits...

The Affordable Care Act—Countdown to Compliance for Employers, Week 13: IRS Notice 2014-49 Offers Useful Guidance on Changes in...

For purposes of complying with the Affordable Care Act’s employer shared responsibility rules (which are codified in Internal Revenue Code § 4980H), employers must identify their “full-time employees.” Final regulations...more

Eversheds Sutherland (US) LLP

Legal Alert: New PPACA-related “Family Status” Changes for Cafeteria Plans

The Internal Revenue Service has issued Notice 2014-55 to permit new health plan elections in two situations where they were not previously allowed. ...more

Dickinson Wright

Penalties and Measuring Periods for Large Employers - How to Assess Potential Liability under the Affordable Care Act

Dickinson Wright on

Under the Affordable Care Act (“ACA”), a large employer is subject to penalties if it fails to offer to full-time employees and their dependents health coverage or if the coverage that it offers is not affordable or does not...more

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