The start date for employer reporting requirements under the ACA has now been pushed back to 2015. In response, the IRS has stated that it will release proposed rules for these requirements later this summer. As a result, employers will have additional time to prepare for the new law. They also will not be penalized for failing to comply with ACA reporting requirements for 2014.
The IRS notice also provides a clue as to how it may handle penalties under the ACA. Starting in 2015, certain employers must offer affordable coverage to their full-time employees. If they do not, and any of their full-time employees receive a premium tax credit, they may have to pay a penalty. But, employers will generally not know whether their employees received a premium tax credit. Thus, the IRS has indicated that it may inform employers if their full-time employees received a premium tax credit. If this is the case, employers may not have to determine if their employees have received premium tax credits.
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