Employee Benefits Advisory – IRS Issues Pay or Play Enforcement Guidance
On Nov. 2, 2017, the IRS updated its Q&As on the ACA’s employer shared responsibility rules to include information on enforcement. These Q&As indicate that, for the 2015 calendar year, the IRS plans to begin issuing letters informing employers of their potential liability for an employer shared responsibility penalty, if any, in late 2017. They also provide guidance on penalty enforcement procedures.
The ACA Compliance Bulletin below provides an overview of the IRS’ guidance