| [Guidance Overview] IRS Continues Aggressive Course of Proposing Penalties with Letters 226J “[If] the employer’s offer of minimum value coverage to an employee is less than or equal to the product of the federal poverty line and the affordability threshold for that particular year the employee cannot trigger an ACA penalty. This … is true even if the employer does not insert the federal poverty line affordability safe harbor code, 2G, in line 16 of the Form 1095-C…. [T]he IRS is apparently attempting to penalize employers under [IRC] section 4980H on grounds there is no basis for under the law.” MORE >> Accord |
