On October 17, 2024, the IRS issued two Notices: one regarding preventive care services that an HSA-compatible high deductible health plan (“HDHP”) can cover on a pre-deductible basis and another allowing the cost of condoms...more
On October 22, 2024, the IRS issued Rev. Proc. 2024-40, which announces the 2025 indexed limits for certain health and welfare benefits. This is in addition to the limits that the IRS announced on May 9, 2024 in Rev. Proc....more
On April 16, 2024, the IRS issued Fact Sheet 2024-13, which includes FAQs addressing the tax treatment of employer-provided work-life referral services. The FAQs generally provide that the value of these services can be...more
On November 9, 2023, the IRS issued Rev. Proc. 2023-34, which announces the 2024 indexed limits for certain health and welfare benefits. This is in addition to the limits that the IRS announced on May 16, 2023 in Rev. Proc....more
On July 7, the Departments of Labor, Treasury, and Health and Human Services published a proposed rule (“Proposed Rule”) regarding, among other things, the requirements for fixed and hospital indemnity insurance to be...more
On June 23, 2023, the IRS issued Notice 2023-37 (the “2023 Notice”) regarding COVID-19-related coverage for HSA-compatible high-deductible health plans (“HDHPs”) and preventive care for HDHP purposes in light of the district...more
On June 8, 2023, the IRS released Chief Counsel Advice 202323006 (the “CCA”) addressing the tax treatment of wellness indemnity payments made by employer-funded fixed indemnity insurance policies. The CCA generally provides...more
On April 28, 2023, the Internal Revenue Service (“IRS”) Office of Chief Counsel issued a Chief Counsel Advice (“CCA”) explaining the requirements for claim substantiation for health and dependent care flexible spending...more
Over the years, many plan sponsors have accumulated surplus assets in their pension and welfare benefit programs for various reasons. Typically, surplus assets have been generated in these mature programs through some...more
On March 28, the Biden Administration submitted its Fiscal Year 2023 budget proposals reflecting its budget and tax policy priorities, which could surface when Congress resumes work on budget reconciliation. While it is...more
On October 6, 2021, the IRS released Notice 2021-58 (the “Notice”), which provides yet another round of guidance on the application of extended deadlines for COBRA elections and payments due to COVID-19. This guidance expands...more
On July 26, 2021, the IRS released Notice 2021-46 (the “Notice”), which provides new guidance on the 100% COBRA premium subsidies (the “Subsidies”) and the related tax credit under the American Rescue Plan Act of 2021 (March...more
On May 18, 2021, the IRS released its highly anticipated guidance on the 100% COBRA premium subsidies (the “Subsidy”) and the related tax credit under the American Rescue Plan Act of 2021 (March 11, 2021) (“ARPA”) in Notice...more
On February 18, 2021, the IRS released Notice 2021-15 (the “Notice”) interpreting section 214 of the Taxpayer Certainty and Disaster Tax Relief Act of 2020 (the “Act”), enacted as Division EE of the Consolidated...more
The IRS recently issued Notice 2020-46 that provides for a special leave donation program available for the COVID-19 pandemic. This brings the total to three tax-favored leave programs that are currently available to...more
On Monday, June 8, 2020, the Treasury Department (“Treasury”) and the Internal Revenue Service (“IRS”) released Proposed Regulations addressing the tax treatment of amounts paid for two unique types of medical arrangements –...more
The IRS released two Notices this week related to cafeteria plans and flexible spending arrangements (“FSAs”). Notice 2020-29 provides relief for cafeteria plans in response to the current COVID-19 pandemic, and Notice...more