"The indexing under the Cadillac Tax will continue while the tax is delayed so that the dollar limits in effect in 2020 will reflect application of indexing had the delay not been enacted. Of perhaps greater significance, the Act makes the Cadillac Tax deductible which will lessen the impact of the tax for certain employers.... [T]he IRS noted that employers and other coverage providers that do not meet the extended due dates [for ACA reporting] are still encouraged to furnish and file, and the IRS will take such steps into consideration when determining whether to abate penalties for reasonable cause.... The IRS also noted that it will take into account the extent to which the employer or other coverage provider is taking steps to ensure that it is able to comply with the reporting requirements for 2016."

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