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 April 7, 2021, the Department of Labor (“DOL”) released initial guidance regarding the 100% COBRA premium subsidies under the American Rescue Plan Act of 2021 (“ARP”), and also issued model notices that can be used in...more
In the early morning hours of February 27, the House of Representatives narrowly passed H.R. 1319, the American Rescue Plan Act (the “Rescue Plan”), by a vote of 219-212. The Senate will now take up the sweeping $1.9 trillion...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
As the COVID-19 pandemic began to overwhelm the country last spring, the Departments of Labor (“DOL”) and Treasury (together, the “Departments”) became concerned that the disruption caused by the pandemic would create...more
Recently, plaintiffs’ firms have filed a flurry of class action lawsuits against employers, alleging violations of COBRA’s election notice requirements and seeking statutory and other penalties. ...more