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IRS Proposes Changes to Affordable Care Act Lookback and Cafeteria Plan Rules

The IRS issued two notices proposing to change the rules for when a taxpayer can revoke health care coverage in a cafeteria plan and enroll in a plan on the Health Insurance Marketplace exchanges, and how to measure the lookback period for determining who is a full-time employee when an employee changes positions within the same employer group.

Minimum Essential Coverage, Other Health Care Reform Guidance Issued

The IRS released health care guidance, including final regulations on minimum essential coverage, a list of hardship exemptions from individual shared-responsibility penalty, and indexed adjustments for certain calculations under the premium tax credit.

IRS Fills in Details of One-a-Year IRA Rollover Rule

The IRS clarified how the recently announced change in how it interprets the statutory one-rollover-per-year rule for IRAs will affect 2014 rollovers and how the rules will apply starting in 2015.

Health Insurance Reporting Gap May Hurt Wealthy Clients

As of the date of this writing, however, questions of substantiating coverage for 2014 remain unanswered, meaning practitioners and their clients should be taking action to avoid substantial potential penalties under PPACA.

FICA Taxation of Nonqualified Deferred Compensation Arrangements

With the passage of the Patient Protection and Affordable Care Act, which provided for an increase in the Medicare tax rate for certain high earners who are members of the ERISA “top hat” group, and recent discussions about the status of Social Security and Medicare funding, it is appropriate to review the rules in Sec. 3121(v)(2) governing FICA taxation.

Appellate Courts Reach Conflicting Decisions on Premium Tax Credit Regs.

On the same day, the D.C. Circuit and Fourth Circuit Courts of Appeals issued decisions on whether Regs. Sec. 1.36B-2(a)(1), which authorizes a premium tax credit for insurance purchased on health insurance exchanges established by the federal government, is a valid regulation.

IRS Issues Guidance on Health Insurance Premium Tax Credits

The IRS issued regulations and revenue procedures addressing how to calculate the Sec. 36B premium tax credit, including how the credit is calculated in conjunction with the Sec. 162(l) deduction for health insurance premiums of self-employed individuals.

IRS Signals PPACA Compliance Issues for 2015

This month, the IRS made several updates to the Internal Revenue Manual that provide insight on the notices and enforcement methods the Service will use next tax season to ensure taxpayers comply with the health care law.

Guidance Issued on Small-Employer Premium Tax Credit

IRS final regulations provide guidance on how small employers determine full-time-equivalent employees and average annual wages, how to calculate the credit, and what is a “qualifying arrangement” for purposes of the credit.