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Treasury/IRS Take First Step in Implementing 40% High-Cost 'Cadillac' Excise Tax with Notice 2015-16 (PDF)
Groom Law Group Link to more items from this source
[Guidance Overview]
Mar. 2, 2015

6 pages. "[T]he projected schedule means that taxpayers will have several opportunities to weigh in on the rules that will eventually apply to the 40% Excise Tax. But a protracted timeline also may mean that Treasury/IRS believe they will need to develop complex rules for implementation and administration of the Tax. This could mean that by the time final rules are published, employers, insurers, plan administrators and others impacted by the Tax may have very little time in which to implement necessary administrative processes to meet reporting obligations and little ability to plan for the economic impact of the Tax on their businesses. Affected parties may want to begin planning now based on [Notice 2015-16], since it gives the first clear indication of the views of Treasury/IRS on a number of significant issues."

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