United States: Determination Of Employer "Pay Or Play" Assessment Under Affordable Care Act Cast Into Doubt Following Recent Court Split
As employers prepare to comply with the Affordable Care Act’s employer shared responsibility provision (or “Pay or Play” requirement) under Section 4980H of the Internal Revenue Code (the “Code”), two recent conflicting Court of Appeals decisions regarding the availability of the premium tax credit to purchase Marketplace / Exchange coverage could impact the Section 4980H’s employer assessment provision. 1 Section 4980H permits the Internal Revenue Service (“IRS”) to assess one of two payments on […]