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ERISA Industry Committee Comment Letter to IRS on Notice 2015-52, ACA 40% Excise Tax (PDF)
The ERISA Industry Committee [ERIC]Link to more items from this source
Oct. 1, 2015

12 pages. "[E]mployers and their administrators and their insurance carriers need to assess and avoid the risk of Code section 4980I excise taxes in advance, and the entire excise tax process should be designed to support these advance determinations. Plan sponsors need to know the excise tax threshold amounts and the value of their health plan coverage before the applicable taxable period, not after. Plan sponsors need to have time to adjust their plan designs, and to reduce extraneous excise tax 'costs' before the applicable taxable period, not after. If a plan sponsor has excise tax risk exposure, the amount of that risk should be known with reasonable accuracy before the applicable taxable period, not after."

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