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Employers, Non-Discrimination Rules and the 'Cadillac Tax'
Pepper Hamilton LLP Link to more items from this source
Feb. 3, 2014
"[T]he existing Section 105(h) regulations are unclear at best, to say the least. It's difficult to imagine how the IRS will interpret these existing 'rules' to regulate insured arrangements.... [T]he excise tax will present employers who wish to sponsor plans with two alternatives: (a) incorporating the tax into their pricing -- by increasing employer and/or employee contribution -- or (b) by cutting benefits to avoid the tax -- by increasing co-payments or co-insurance paid by the employees."

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