IRS Issues Additional Cadillac Tax Guidance and Requests Comments

Effective for tax years beginning in 2018, the Affordable Care Act (the ?Ç£ACA?Ç¥) imposes a 40 percent excise tax (also known as the ?Ç£Cadillac Tax?Ç¥) on any excess benefit provided under any employer-sponsored health coverage in excess of certain statutory thresholds. The IRS and Treasury Department recently released Notice 2015-52 (the ?Ç£Notice?Ç¥), which discusses various implementation issues raised by the Cadillac Tax. The Notice addresses issues related to identifying the ?Ç£covered providers?Ç¥ that are liable to pay the tax, tax consequences where a covered provider is reimbursed for excise tax payments, employer aggregation issues, tax determination periods, notification and payment issues, age and gender adjustments to the statutory limits, and other issues not covered under prior guidance. The IRS is requesting comments by October 1, 2015, and intends to issue proposed regulations following public comment. The Notice is available?áhere.