A recently released redacted report from the Treasury Inspector General for Tax Administration (TIGTA) offers some helpful insights for employers who may be assessed shared responsibility payments because the IRS thinks they...more
Over the past several years, there has been much speculation surrounding the Patient Protection and Affordable Care Act (the "ACA"), including whether it would be repealed in full, only partially, or not at all. Despite this...more
Within the past few weeks, IRS officials have informally indicated that the IRS would begin assessing tax penalties under the Affordable Care Act’s (ACA) employer shared responsibility. The IRS has now updated its Questions...more
Many employers were hopeful that the Code Section 4980H penalties would be repealed now that Republicans control Congress and Trump is in the White House. To date, that has not happened, nor has the IRS announced it will not...more
As 2016 comes to an end, we are pleased to present you with our traditional End of Year Plan Sponsor “To Do” Lists. Like last year, we are presenting our “To Do” Lists in three separate Employee Benefits Updates. Part 1 of...more
It’s the “silly season” on the Hill and a busy season for ACA regulators. This article gives you brief notes about Notice 2015-87, information reporting relief and the § 4980I delay buried in the omnibus spending bill....more
As 2015 comes to an end, we are pleased to present you with our traditional End of Year Plan Sponsor “To Do” Lists. Like last year, we are presenting our “To Do” Lists in three separate Employee Benefits Updates. Part 1 of...more
Beginning in 2015, certain applicable large employers may be assessed a payment as part of the “employer shared responsibility” provisions of the Affordable Care Act (ACA). Payment is assessable if the employer either (1)...more
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
When it comes to mergers and acquisitions involving at least one applicable large employer (ALE), the substantive rules governing employer shared responsibility (under Internal Revenue Code § 4980H) and the corresponding...more
As we reported last week, the IRS recently issued draft 2015 Instructions for Forms 1094-C and 1095-C. These instructions are of interest to applicable large employers who must report their compliance with the Affordable Care...more