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Willis Human Capital Practice, National Legal & Research Group
In the Health Care Reform Update from February 23, 2015, “Agencies Release Guidance on Variety
of Health Care Reform Issues,” Willis’ National Legal & Research Group outlined various pieces of
guidance from the Centers of Medicare and Medicaid Services and the Internal Revenue Service.
Among those materials was information about IRS Notice 2015-16.
The Notice was issued as a first step in developing regulatory guidance regarding the excise (Cadillac)
tax on high-cost employer sponsored coverage and described potential approaches to various Cadillac
tax issues which the IRS might include in future proposed regulations. The IRS issued a “Request for
Comments” on issues such as definition of applicable coverage, the cost of applicable coverage, and
the application of the annual dollar limit on the cost of applicable coverage.
Willis is formulating a response to the Notice 2015-16 “Request for Comments” as part of an industry
group, but we recognize that some plan sponsors may prefer to provide their own comments to the
IRS. In that case, public comments must be received by May 15, 2015. All comments should be sent
By email to:
Notice. comments@irscounsel.treas.gov
(please include “Notice 2015-16” in the subject line of the email)
OR
By U.S. Postal Service to:
CC:PA:LPD:PR (Notice 2015-16)
Room 5203
Internal Revenue Service
P.O. Box 7604
Ben Franklin Station
Washington, DC 20044
Willis has provided a template letter that must be customized by plan sponsors who wish to submit
comments to the IRS. The template is available here:
https://welcome.willis.com/nlrgclientcommunication/Shared%20Documents/Sample%20letter%20for
%20Request%20for%20Comments_Cadillac%20Tax.docx.
This information is not intended to represent legal or tax advice and has been prepared solely for informational
purposes. You may wish to consult your attorney or tax adviser regarding issues raised in this publication.
WEEK OF APRIL 13, 2015:
Health Care Reform Update - Cadillac Tax Comments Due May
15

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Health Care Reform Developments Week of April 13, 2015

  • 1. - 1 - Willis Human Capital Practice, National Legal & Research Group In the Health Care Reform Update from February 23, 2015, “Agencies Release Guidance on Variety of Health Care Reform Issues,” Willis’ National Legal & Research Group outlined various pieces of guidance from the Centers of Medicare and Medicaid Services and the Internal Revenue Service. Among those materials was information about IRS Notice 2015-16. The Notice was issued as a first step in developing regulatory guidance regarding the excise (Cadillac) tax on high-cost employer sponsored coverage and described potential approaches to various Cadillac tax issues which the IRS might include in future proposed regulations. The IRS issued a “Request for Comments” on issues such as definition of applicable coverage, the cost of applicable coverage, and the application of the annual dollar limit on the cost of applicable coverage. Willis is formulating a response to the Notice 2015-16 “Request for Comments” as part of an industry group, but we recognize that some plan sponsors may prefer to provide their own comments to the IRS. In that case, public comments must be received by May 15, 2015. All comments should be sent By email to: Notice. comments@irscounsel.treas.gov (please include “Notice 2015-16” in the subject line of the email) OR By U.S. Postal Service to: CC:PA:LPD:PR (Notice 2015-16) Room 5203 Internal Revenue Service P.O. Box 7604 Ben Franklin Station Washington, DC 20044 Willis has provided a template letter that must be customized by plan sponsors who wish to submit comments to the IRS. The template is available here: https://welcome.willis.com/nlrgclientcommunication/Shared%20Documents/Sample%20letter%20for %20Request%20for%20Comments_Cadillac%20Tax.docx. This information is not intended to represent legal or tax advice and has been prepared solely for informational purposes. You may wish to consult your attorney or tax adviser regarding issues raised in this publication. WEEK OF APRIL 13, 2015: Health Care Reform Update - Cadillac Tax Comments Due May 15