In an unexpected memo from the IRS, the Office of Chief Counsel has concluded that the filing of Affordable Care Act (“ACA”) returns does not start the statute of limitations on the Employer Shared Responsibility Payments (“ESRP”) that may be owed by employers with 50 or more full-time (or equivalent) employees. ESRP is also commonly …
The Affordable Care Act Reporting Requirements Still Loom: Last-Minute Compliance Tips for Paper and Electronic Filers
As we reminded employers back in December, the IRS has extended the Affordable Care Act (“ACA”) deadline for health plan sponsors to furnish individuals IRS Forms 1095-B and 1095-C until March 2, 2020. However, it did not extend the due date for filing the 2019 Forms 1094-B, 1095-B, 1094-C, or 1095-C with the IRS. Those …
Changes Affecting Employer-Sponsored Health Plans in the 2020 Appropriations Act
The 2020 appropriations act, which was signed into law by the President on December 20, 2019, contains a mix of good and bad news for employer-sponsored health plans. On the good news side of the ledger, several taxes imposed by the Affordable Care Act have been repealed, as follows: To literally no one’s surprise, the …
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What to Do if Your Company is Close to the Affordable Care Act’s 50 Full-time Employee Threshold
Having recently helped a client determine if it employed on average more than 50 employees per month in a calendar year and therefore was an applicable large employer (“ALE”) subject to the Affordable Care Act (“ACA”) in the following calendar year, I had many opportunities to see the complexities of the ACA’s rules in operation. …