Seyfarth Synopsis: Although it is not law yet, according to the must-pass spending legislation passed by both the House and Senate, it looks like the infamous Cadillac Tax and the Annual Fee on Health Insurance Providers (HIP...more
Seyfarth Synopsis: Two new Executive Orders and a corresponding decision in the Supreme Court effectively limit how agencies can utilize guidance against private parties—the agency must rely only on guidance that is fully...more
On May 1, 2019, the Internal Revenue Service (IRS) issued guidance re-opening its storied determination letter program to hybrid plans and certain plans impacted by plan mergers....more