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Proposed Rules for Expatriate Health Plans and Certain Excepted Benefits under ACA
Kilpatrick Townsend 
[Guidance Overview] June 16, 2016
"It is important to remember that expatriates may still be subject to the individual mandate (but these plans may qualify as minimum essential coverage), employers still need to comply with the employer penalty rules, and the health plan reporting obligations through Forms 1094/1095 continue to apply to those covered by these plans."
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