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Form and Substance: Why the Form of a Transaction is so Critical to Employee Benefits and Executive Compensation Strategy

The form of a corporate transaction sets the stage for the employee benefits and executive compensation (EBEC) strategy – in the scope of due diligence and purchase agreement negotiations and post-closing activity. The charts...more

Cures Act Lets Small Employers Reiumburse Premiums

On December 13, 2016, President Obama signed into law the 21st Century Cures Act, which allows small employers to maintain health reimbursement arrangements (HRAs) for the purpose of reimbursing employees for the cost of...more

Cover Letters: The Key to Simplifying ERISA Plan Document Requests

Sponsors of qualified retirement plans and group health plans may receive tens, if not hundreds, of plan document requests every year. Responding to these requests in accordance with the rules set forth under the Employee...more

Affordable Care Act Reporting is Here (But May be a Little Late…)

The Affordable Care Act requires “applicable large employers” (generally, employers with 50 or more full-time employees and full-time employee equivalents) to provide individual statements to their full-time employees and to...more

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

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

Two Important Deadlines Approaching for Self-Insured Group Health Plans

If you sponsor a self-insured group health plan, then November includes two important deadlines: (1) you must obtain a health plan identifier for your plan, and (2) you must report the number of participants for whom a...more

Final “Pay or Play” Regulations Provide Transition Relief for Non-Calendar Year Plans

Last week, the IRS issued final regulations that provide additional guidance on the new “pay or play” rules (also called the employer shared responsibility rules) that will generally apply to employers’ group health plans...more

“We have to offer COBRA, When?” The “In Anticipation of Divorce” Rule

Most plan administrators know that the recipe for a group health plan’s COBRA obligation includes three ingredients – a qualifying event that occurs while the individual is covered by the plan that triggers a loss of such...more

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