Nicholas Pension Consultants
Nova 401(k) Associates
Compensation Strategies Group, Ltd.
“BenefitsLink continues to be the most valuable resource we have at the firm.”
-- An attorney subscriber
|American Bankers Association HSA Council Comment Letter to IRS on 'Cadillac Tax' (PDF)|
American Bankers Association Health Savings Account Council
May 19, 2015
"[T]his ability to use your own money as you see fit is what constitutes ownership and ownership has to mean something; it can't be the case that the excise tax rules lump HSAs into the same category as every other product, because HSAs are the only product where someone other than the employer owns a portion of the dollars being counted.... [T]he IRS has the necessary discretionary authority to characterize employee contributions to the employee's HSA, even if facilitated by the employer through Section 106 authority, as 'excludable' without also being included in the definition of 'applicable coverage' precisely because employers don't own any of the money in an employee's HSA."
|Please click here to report this link if it is broken (for example, if you see a "404 File Not Found" error message after you click on the link above).|
|An important word about authorship: BenefitsLink® is providing a hypertext link to the item shown above, but is not the author of the item (unless otherwise specified).|