IRS notice seeks comments on ACA "Cadillac Tax" issues
By Milliman Employee Benefits Research Group
11 March 2015
Notice 2015-16 provides background information, definitions, and potential approaches the IRS may incorporate into future rule-making regarding the excise tax. The notice invites comments on three main areas relating to applicable coverage: the definition, cost determination, and the application of the annual dollar limit to the cost. There will be a separate IRS notice that will discuss and seek comments on the procedures for calculating and assessing the excise tax.