News & Analysis as of August 24, 2025

U.S. Treasury

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The Patient Protection and Affordable Care Act (PPAC), also known as Obamacare, is a United States federal statute passed in March of 2010. The Act creates a nationwide insurance system and provides federal... more +

IRS roundup: July 12 – July 29, 2025

McDermott Will & Schulte on 8/18/2025

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for July 12, 2025 – July 29, 2025. July 15, 2025: The IRS issued Revenue Ruling 2025-14, providing prescribed rates for...more

Welcome (But Last Minute) Relief for Prescription Drug Reporting Originally Due December 27

McDermott Will & Schulte on 12/29/2022

Section 204 of Title II of Division BB of the Consolidated Appropriations Act, 2021 amended the Internal Revenue Code, the Employee Retirement Income Security Act of 1974 and the Public Health Service Act to add rules...more

New Guidance Delays Some Key CAA and Other Health Benefit Effective Dates

Ogletree, Deakins, Nash, Smoak & Stewart,... on 8/24/2021

New regulatory guidance from three federal agencies that enforce private-sector benefits laws will make employers’ daunting 2021 health benefit to-do lists slightly - but only slightly - more manageable heading into 2022....more

The Affordable Care Act’s Reporting Requirements for Carriers and Employers (Part 23 of 24): Notice 2016-4 Postpones Reporting and...

Mintz - Employment, Labor & Benefits... on 12/29/2015

Under the Affordable Care Act’s reporting requirements that have been the subject of this series, statements to responsible individuals (a/k/a “employees”)—i.e., Forms 1095-B and 1095-C—must be furnished on or before January...more

The Affordable Care Act’s Reporting Requirements for Carriers and Employers (Part 16 of 24): Reporting for, and Clearing Up...

Mintz - Employment, Labor & Benefits... on 11/3/2015

In an earlier post, we reported on a troubling development in the draft 2015 instructions for Forms 1094-B and 1095-B which, if adopted, would have required sponsors of Health Reimbursement Arrangements (“HRA”) to issue...more

The Affordable Care Act’s Reporting Requirements for Carriers and Employers (Part 15 of 24): Coding Form 1095-C, Part II for...

Mintz - Employment, Labor & Benefits... on 10/29/2015

As we noted in a previous post, the recently issued final 2015 Instructions for Forms 1094-C and 1095-C changed certain of the rules relating to the reporting for offers of COBRA coverage where the COBRA qualifying event...more

The Affordable Care Act’s Reporting Requirements for Carriers and Employers (Part 13 of 24): Coding Form 1095-C, Part II for...

Mintz - Employment, Labor & Benefits... on 10/14/2015

Compliance with the Affordable Care Act’s (ACA) employer shared responsibility rules requires that applicable large employers identify their full-time employees. A “full-time employee” for this purpose is an employee who...more

The Affordable Care Act’s Reporting Requirements for Carriers and Employers (Part 10 of 24): IRS Issues Final Form 2015...

Mintz - Employment, Labor & Benefits... on 9/22/2015

The IRS recently issued final instructions for Forms 1094-B and 1095-B and Forms 1094-C and 1095-C . The 2015 Instructions for Forms 1094-B and 1095-B implement a suggestion we made in a previous post relating to the...more

The Affordable Care Act’s Reporting Requirements for Carriers and Employers (Part 7 of 24): Mergers and Acquisitions

Mintz - Employment, Labor & Benefits... on 9/1/2015

When it comes to mergers and acquisitions involving at least one applicable large employer (ALE), the substantive rules governing employer shared responsibility (under Internal Revenue Code § 4980H) and the corresponding...more

The ERISA Litigation Newsletter - August 2015

Proskauer Rose LLP on 8/28/2015

Editor's Overview - As the summer draws to a close, this month's Newsletter previews three cases that the U.S. Supreme Court already has agreed to hear that ought to be of particular interest to ERISA plan sponsors and...more

Treasury Department/IRS Issue Proposed Rules on Employer Reporting of Health Insurance Coverage Under the Affordable Care Act

Mintz - Employment, Labor & Benefits... on 10/22/2013

In addition to imposing substantive requirements on health insurance issuers in the group and individual markets and employer-sponsored group health plans, the Patient Protection and Affordable Care Act (Act) imposes three...more

Health Care Reform Update -- September 9th, 2013

Mintz - Health Care Viewpoints on 9/10/2013

In This Issue: Leading the News; Implementation of the Affordable Care Act; Other HHS and Federal Regulatory Initiatives; Other Congressional and State Initiatives; Other Health Care News; and Hearings and Mark-Ups...more

Proposed Employer Tax Rules Available For Obamacare

Hinshaw & Culbertson LLP on 9/10/2013

The U.S. Department of the Treasury and the Internal Revenue Service have published proposed rules establishing reporting requirements for employers and insurers under the Affordable Care Act (“ACA”), or Obamacare....more

Employers Face Compliance Options In Lights Of Delayed Implementation Of Pay Or Pay Mandate Under The ACA, But Other ACA...

Laner Muchin, Ltd. on 7/15/2013

On July 2, 2013, the Treasury Department’s announced that enforcement of the "Pay or Play" mandate under the ACA will be delayed until January 1, 2015. This announcement was followed by a brief notice from the IRS which...more

Large Employer Reporting Requirements and Penalties Mandated by Affordable Care Act Delayed One Year

King & Spalding on 7/9/2013

The Treasury Department announced on Tuesday, July 2, 2013, that reporting requirements and penalties imposed on large employers under the Affordable Care Act (ACA) would be delayed one year, until January 1, 2015. ...more

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