"The transition relief exempts employer payment plans from ... excise taxes [1] for 2014 for employers that are not 'applicable large employers' (ALEs) for 2014, and [2] for January 1 through June 30, 2015 for employers that are not ALEs for 2015. After June 30, 2015, all employers may be liable for excise taxes if they continue these 'employer payment plans' in effect.... The IRS transition relief exempts from the above excise taxes an arrangement that reimburses or pays for the premiums for individual medical insurance policies of 2% or more shareholders, until the later of the date further guidance is issued or December 31, 2015.... This transition relief does not apply to reimbursements or payments for the premiums for individual health insurance policies for employees of an S corporation who are not 2% or more shareholders."

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