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Under the ACA, Do Employers Need to Offer Coverage to Employees Working Abroad?
Graydon Head & Ritchey LLP 
Jan. 4, 2016
"Employers that only employ U.S. citizens working abroad, being paid from foreign sources, are likely not subject to the ACA mandates.... [F]or employers with employees working domestically and abroad, the analysis hinges on where each employee's hours of service were performed and the source of the employee's compensation."
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