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Potential Year-End Amendment Required for Cafeteria Plans
Choate Hall & Stewart LLP 
[Guidance Overview] Dec. 18, 2015 "[IRS Notice 2015-86] confirms that Obergefell has minimal or no impact on most types of plans because of previously required same-sex marriage plan changes resulting from the United States v. Windsor decision. However, the IRS identified and provided guidance on a situation unique to cafeteria plans ... Employers who, in response to Obergefell, began providing coverage midyear under their cafeteria plan to the same-sex spouses of their employees, may need to amend their cafeteria plans by December 31, 2015." MORE >> |
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