News & Analysis as of

Internal Revenue Service Tax Liability Patient Protection and Affordable Care Act (PPACA)

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
Pullman & Comley - Labor, Employment and...

Federal Court Decision Reshapes ACA Enforcement by HHS and IRS

The recent federal district court decision in Faulk Company, Inc. v. Xavier Becerra, et al., No. 24-cv-00609-P (N.D. Tex. 2025) significantly alters the primary mechanism used by the U.S. Department of Health and Human...more

Bricker Graydon LLP

What, Me PCORI? - Fee Update for Self-Funded Plans

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While the Patient-Centered Outcomes Research Initiative (“PCORI”) fee was updated at the turn of the year, the fee is not actually paid until July.  For those of you that forgot about the fee, this is your reminder to start...more

Jackson Walker

New Statute of Limitation Will Help Limit ACA Liabilities in M&A Deals, But Buyers Should Remain Diligent

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To the satisfaction of companies routinely engaged in mergers and acquisitions, U.S. Congress recently amended the tax code through the Employer Reporting Improvement Act to add a six-year statute of limitations on the...more

Bass, Berry & Sims PLC

2025 Changes to ACA Employer Information Reporting Obligations and the Employer Shared Responsibility Penalties

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In December 2024, Congress and President Biden passed two laws—the Paperwork Burden Reduction Act (PBRA) and the Employer Reporting Improvement Act (ERIA)—that made important changes to employers’ responsibilities regarding...more

Freeman Law

Tax Court in Brief | Henry v. Comm’r | Affordable Care Act and Deficiency for Amounts of Advance Premium Tax Credits

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Summary: From early 2015 and through 2016 Marie Henry (“Henry”) was unemployed and in a terrible financial, physical, and mental state. To get by, she made early withdrawals from a retirement plan. She was enrolled in health...more

McAfee & Taft

IRS announces relief for certain Form 1094/1095 reporting requirements

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In a similar move as in previous years, the IRS has issued relief from certain Form 1094-C and 1095-C reporting requirements under the Affordable Care Act relating to employee health plans, as well as relief from certain...more

BCLP

Employer Shared Responsibility Payments May Have No Statute of Limitations

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In Chief Counsel Memorandum 20200801F, released on February 21, 2020, the IRS established its position that no statute of limitations applies to employer shared responsibility payments that may be assessed under Section 4980H...more

Holland & Knight LLP

Senate Finance Committee Begins Review of Nonprofit Hospitals

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• Based on a new review of nonprofit hospitals by Senate Finance Committee Chairman Charles Grassley (R-Iowa), a congressional investigation is expected that directly requests a number of specific hospitals to answer...more

Ballard Spahr LLP

IRS Extends ACA Reporting Deadline

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As it did last year, the IRS has extended the deadline for furnishing Forms 1095-B and 1095-C to individuals by 30 days. This reprieve will allow employers, health insurers, and other plan sponsors to distribute the forms on...more

Ballard Spahr LLP

IRS Prepares to Enforce ACA Employer Mandate

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The IRS has announced its intent to begin enforcing the employer-shared responsibility provisions (otherwise known as the employer mandate or pay-or-play provisions) of the Affordable Care Act for the 2015 calendar year....more

Holland & Knight LLP

Affordable Care Act: Understanding Employer Notices From the Marketplaces

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The Affordable Care Act (ACA) established Health Insurance Marketplaces (also called Exchanges) where individuals can shop and enroll in health coverage. Individuals who meet certain criteria are eligible for premium...more

Alston & Bird

A&B Healthcare Week in Review

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I. REGULATIONS, NOTICES, & GUIDANCE - On April 15, 2016, the Food and Drug Administration (FDA) issued a proposed rule entitled, “Applications for Approval and Combinations of Active Ingredients Under Consideration for...more

Balch & Bingham LLP

Healthcare.gov: No 2015 Employer Subsidy Notices

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On September 18, 2015, the Centers for Medicare and Medicaid Services (CMS) published a set of “Frequently Asked Questions Regarding the Federally-Facilitated Marketplace’s (FFM) 2016 Employer Notice Program.”...more

Franczek P.C.

IRS Issues Second Notice on Cadillac Tax

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On July 30, the IRS issued Notice 2015-52, which provides guidance regarding the “Cadillac Tax” provision of the Affordable Care Act (ACA). Earlier this year, the IRS issued Notice 2015- 16, which represented the first...more

Fisher Phillips

New U.S. Guidance On Expatriate Health Plans

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As discussed in a prior post, the U.S. Internal Revenue Service (“IRS”) is currently in the process of finalizing its regulations implementing the Affordable Care Act’s (“ACA”) “Employer Mandate.” The Employer Mandate, which...more

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