With two seemingly simple and straightforward definitions in the final regulations implementing the Affordable Care Act’s pay-or-play rules—i.e., definitions of “employer” and “employee”— the Treasury Department and IRS have...more
The Internal Revenue Service has released a series of FAQs to answer several outstanding questions following the U.S. Supreme Court’s ruling in Windsor, which struck down Section 3 of the Defense of Marriage Act. The most...more
As we approach the end of the year, employers and plan sponsors of qualified retirement plans and health and welfare plans should take time to meet various upcoming deadlines. Failure to comply with the deadlines may result...more
The Internal Revenue Service has issued proposed regulations on reporting requirements under the Affordable Care Act (ACA). The regulations, released on September 9, 2013, address two separate ACA reporting requirements: one...more
The Affordable Care Act added the so-called “Play or Pay” mandate or “Employer Shared Responsibility” provisions to the Internal Revenue Code (the Code). Starting in 2014, certain employers may be subject to a penalty tax,...more
With the re-election of President Obama and the Supreme Court's recent decision upholding portions of the Affordable Care Act (the "ACA"), health care reform is here to stay for the foreseeable future. Though limited...more
On January 3, 2012, the Internal Revenue Service ("IRS") released Notice 2012-9, which restates and clarifies its prior guidance on the requirement under the Affordable Care Act to report the cost of employer-sponsored health...more
On March 29, 2011, the Internal Revenue Service (“IRS”) released Notice 2011-28, which provides guidance to employers on the requirement under the Affordable Care Act (the “Act”) to report the cost of employer-sponsored...more