"[1] Health FSA: The statute specifically provides that both employer contributions (including through flex credits) and employee salary reduction contributions will count toward the Cadillac tax limit. [2] HSA: The statute states that 'employer contributions' to an HSA count toward the Cadillac tax limit. However, the IRS has determined that because employee pre-tax salary reduction contributions to an HSA are treated as employer contributions for tax purposes, both employer and employee contributions will count toward the Cadillac tax.... [3] HRA amounts -- which are funded solely by the employer -- will also count toward the Cadillac tax limit. The IRS is considering how best to determine the cost of coverage provided under an HRA, including potentially relying on the amounts made newly available to a participant each year (and not carryover amounts made available prior to 2018)."