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IRS Releases New COBRA Subsidy Guidance . . . With Less Than A Week Until Forms 941 Are Due!

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

IRS Uncoils COBRA Subsidy Guidance!

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

It’s No Stretch to Say That IRS Guidance Makes FSAs More Flexible

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

Congressional Pushback to Recent IRS Guidance on Deductibility of Expenses Related to PPP Loans

The Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”) provided employers valuable relief from the economic stress caused by the COVID-19 pandemic, by creating access to loans under the Paycheck Protection...more

Special 2020 W-2 Reporting Mandated for Qualified Sick and Family Leave Wages

On July 8, 2020, the IRS released Notice 2020-54 (the “Notice”), which mandates 2020 W-2 reporting of qualified sick and family leave wages paid to employees under the Families First Coronavirus Response Act (the Act). ...more

Leave Donation Programs for COVID-19

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

Direct Primary Care Arrangements and Health Care Sharing Ministries Receive Favorable Tax Treatment Under Proposed Regulations

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

Ch-Ch-Ch-Changes (In Elections and Grace Periods)

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

Significant Developments Affecting VEBAs – Final IRS Rules Clarify Unrelated Business Taxable Income (“UBTI”) Issues But Renew...

In December, the IRS/Treasury (“IRS”) published final rules addressing how employers that fund health and welfare benefits through a VEBA (i.e., a voluntary employees’ beneficiary association described in Section 501(c)(9) of...more

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