Jump to content

Search the Community

Showing results for tags '50+ FTEs but not in one compa'.

  • Search By Tags

    Type tags separated by commas.
  • Search By Author

Content Type

Forums (Message Boards)

  • Retirement Plans
    • 401(k) Plans
    • Defined Benefit Plans, Including Cash Balance
    • Retirement Plans in General
    • Distributions and Loans, Other than QDROs
    • IRAs and Roth IRAs
    • 403(b) Plans, Accounts or Annuities
    • Cross-Tested Plans
    • Correction of Plan Defects
    • SEP, SARSEP and SIMPLE Plans
    • Qualified Domestic Relations Orders (QDROs)
    • Employee Stock Ownership Plans (ESOPs)
    • Plan Terminations
    • Governmental Plans
    • Plan Document Amendments
    • 457 Plans
    • Investment Issues (Including Self-Directed)
    • Operating a TPA or Consulting Firm
    • Estate Planning Aspects of IRAs and Retirement Plans
    • Continuing Professional Education
    • ERPA (Enrolled Retirement Plan Agent)
  • Issues Spanning Multiple Types of Plans
    • Form 5500
    • Communication and Disclosure to Participants
    • Litigation and Claims
    • Church Plans
    • Securities Law Aspects of Employee Benefit Plans
    • Mergers and Acquisitions
    • Multiemployer Plans
    • International, Expat Benefits
    • Miscellaneous Kinds of Benefits
  • Health & Welfare Plans
    • Cafeteria Plans
    • Health Plans (Including ACA, COBRA, HIPAA)
    • Health Savings Accounts (HSAs)
    • VEBAs
    • Other Kinds of Welfare Benefit Plans
  • Executive Comp; Section 409A
    • 409A Issues
    • Nonqualified Deferred Compensation
  • Miscellany: Other Than Employee Benefits
    • Using the Message Boards (a.k.a. Forums)
    • Humor, Inspiration, Miscellaneous
    • Computers and Other Technology
  • User Groups (Unofficial)
    • ftwilliam.com
    • Relius Administration

Find results in...

Find results that contain...

Date Created

  • Start


Last Updated

  • Start


Filter by number of...


  • Start





Website URL






Found 1 result

  1. To define an employer that might have enough full-time-equivalent employees that it might incur a 'play-or-pay' excise tax on not offering health coverage, Internal Revenue Code section 4980Hc(2)C(i) provides that "[a]ll persons treated as a single employer under subsection (b), c, (m), or (o) of section 414 ... shall be treated as [one] employer." Imagine that there are six non-natural persons (a mix of S corporations, limited-liability companies, and limited partnerships) that are treated as one employer. None of these organizations uses a common paymaster or shares an EIN with any other. None of these organizations combines its Federal income tax return with any other. None of the five flow-through owners makes a personal income tax return with any other. Together, the six organizations have 73 full-time employees. But none has more than 14 employees. Corporation Alpha, which has nine employees, does not offer health coverage to anyone. (If it helps, organizations B, C, D, E, and F also don't offer health coverage to anyone.) Mary, an Alpha employee, gets a tax credit or cost-sharing reduction that subsidizes her Exchange-bought health insurance. Imagine that the Exchange application that Mary completed asked her for her estimate of how many employees her employer has, and she answered what she knew - nine. Unless the Internal Revenue Service has an amazing relational database, does the IRS lack a practical means to assess the excise tax in circumstances like these? Am I just being stupid, or is there a gap in the Government's ability to enforce the 'play-or-pay' idea?
  • Create New...