The maxim that the IRS waits until after noon ET to release guidance worth reading was re-enforced today when the IRS released Notice 2015-17 this afternoon. In Notice 2015-17, the IRS provides transition relief from Code section 4980D excise tax assessed for failure to satisfy market reforms in certain circumstances. The IRS says the Notice 2015-17 transition relief “applies to employer healthcare arrangements that constitute:
- 1. employer payment plans, as described in Notice 2013-54, if the plan is sponsored by an employer that is not an Applicable Large Employer (ALE) under Code section 4980H(c)(2) and Regs. 54.4980H-1(a)(4) and -2;
- 2. S corporation healthcare arrangements for 2-percent shareholder-employees;
- 3. Medicare premium reimbursement arrangements; and
- 4. TRICARE-related health reimbursement arrangements (HRAs).”
Notice 2015-17 is 7 pages long in single-column format, and contains 5 Q&A’s in addition to the transition relief contained in the opening preamble.
And don’t skip the footnotes – in footnotes 1 and 2, the IRS gives us a roadmap to some of the Affordable Care Act guidance.
