IRS Requests Comments on Employer Provisions of Health Care Reform

May 10, 2011
IRS Requesting Comments Health ReformOn May 3rd, the Internal Revenue Service (IRS) requested comments regarding provisions included in the Affordable Care Act that will apply to certain employers starting in 2014.

Notice 2011-36 requests comments on the definitions used to calculate the employer penalty for companies with greater than 50 full-time employees.  In particular, the notice requests comment on possible approaches employers could use to determine who is a full-time employee.

Under the Affordable Care Act, employers with 50 or more full-time employees that do not offer affordable health coverage may be required to pay a penalty.  The law specifically exempts small firms that have fewer than 50 full-time employees.

There are three ways to submit comments.
    1. E-mail to: Notice.Comments@irscounsel.treas.gov. Include “Notice 2011-36” in the subject line.
    2. Mail to: Internal Revenue Service, CC:PA:LPD:PR (Notice 2011-36), Room 5203, P.O. Box 7604, Ben Franklin Station, Washington, DC 20044.
    3. Hand deliver to: CC:PA:LPD:PR (Notice 2011-36), Courier’s Desk, Internal Revenue Service, 1111 Constitution Avenue NW, Washington, DC, between 8 a.m. and 4 p.m., Monday through Friday.
Comments are due June 17, 2011.

Note: None of this should be taken as legal or tax advice. 

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