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IRS Releases Second Notice on Cadillac Tax Implementation Issues

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August 7, 2015

On July 31, 2015, the Internal Revenue Service ("IRS") released Notice 2015-52 (the "Notice"), the second installment in the IRS's process of developing regulatory guidance regarding the ACA's "excise tax on high cost employer-sponsored health coverage" - commonly known as the "Cadillac tax." The Cadillac tax applies starting in 2018, and imposes a 40% nondeductible excise tax on the aggregate cost of "applicable employer-sponsored coverage" in excess of certain statutory limits ($10,200 for self-only coverage and $27,500 for coverage other than self-only).

Waiting on the Supremes

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King v. Burwell Decision

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