With: Nancy Taylor and Danielle White

Last week, on July 2, 2013, the Obama Administration announced a one-year delay in the application of penalties associated with the employer shared responsibility requirements established under the Patient Protection and Affordable Care Act, Pub. L. No. 111-148, and the Health Care and Education Reconciliation Act, Pub. L. No. 111-152 (collectively, the ACA).  The decision came down as a result of the Administration’s simultaneous delay in ACA employer reporting requirements established under Internal Revenue Code (IRC) §§ 6055 and 6056.

This week, on July 9, 2013, the IRS released Notice 2013-45, Transition Relief for 2014 Under (§ 6055 Information Reporting), (§ 6056 Information Reporting) and 4980H (Employer Shared Responsibility Provisions), confirming the Administration’s earlier statements that both reporting requirements under IRC §§ 6055 and 6056 and the application of penalties associated with the employer shared requirements will be subject to transition relief for 2014.  The guidance clarifies that the delay is limited to these provisions only and does not impact implementation of any other ACA requirements.

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