The Employers Council on Flexible Compensation (ECFC) is asking the Internal Revenue Service (IRS) to clarify where flexible savings arrangements (FSAs) fit in with the new Form W-2 health benefits reporting requirements.
John Hickman, a lawyer representing the ECFC, Washington, has made that request in a comment letter on IRS Notice 2011-28, a document gives interim guidance on how employers should comply with the new W-2 reporting requirements created by Section 6051(a)(14) of the Patient Protection and Affordable Care Act of 2010 (PPACA).
PPACA is supposed to impose the Cadillac plan tax in 2018. The 40% tax will apply to health plan value over a specified threshold.
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