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IRS Requests Comments on Application of Employer Shared Responsibility and Nondiscrimination Requirements to Individual Coverage HRAs
Winston & Strawn LLP Link to more items from this source
[Guidance Overview]
Dec. 3, 2018

"The [IRS] recently released proposed regulations regarding the ability to integrate health reimbursement arrangements and other account-based group health plans (HRAs) with individual health insurance coverage. IRS Notice 2018-88 sets forth anticipated guidance and requests comments on the application of the employer shared responsibility requirements in Internal Revenue Code Section 4980H and the nondiscrimination requirements of Code Section 105(h) to such HRAs. The Notice states that it cannot be relied upon by taxpayers with regard to Code Sections 4980H or 105(h), but gives an indication as to the IRS guidance that can be expected on these topics."

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