The BNA Tax and Accounting Center is the only planning resource to offer expert analysis and practice tools from the world's leading tax and accounting authorities along with the rest of the tax resources you need in one, integrated Center.
By Edward I. Leeds, Esq.
Ballard Spahr LLP, Philadelphia, PA
In the Consolidated and Further Continuing Appropriations Act (the recently enacted federal budget bill often known as the "CRomnibus" legislation), Congress has exempted health plans designed to cover expatriates from most of the requirements of the Affordable Care Act. The exemption will generally apply where a group health plan provides significant health coverage and substantially all of the covered employees fall under any of the following categories:
Although the exemption is extensive, expatriate plans must continue to meet certain ACA requirements. For example:
By its terms, the new exemption applies only to health plans issued or renewed on or after July 1, 2015. However, for many expatriate plans, there are currently exemptions in place for market reforms and certain fees and assessments required under the ACA. We would be glad to help you evaluate whether any of the current or future exemptions apply to the health coverage provided to your expatriate employees.
As the federal health care reform effort gained steam, Ballard Spahr attorneys established the Health Care Reform Initiative] to monitor and analyze legislative developments. With federal health care reform now a reality, our attorneys are assisting health care entities and employers in understanding the relevant changes and planning for the future. They also have launched the Health Care Reform Dashboard, an online resource center for news and analysis on developments under the Affordable Care Act.
If you have questions about this alert or other ACA-related considerations, please contact Edward I. Leeds at 215.864.8419 or email@example.com, Brian M. Pinheiro at 215.864.8511 or firstname.lastname@example.org, Jean C. Hemphill at 215.864.8539 or email@example.com, Diane A. Thompson at 424.204.4334 or firstname.lastname@example.org, or any other member of the Employee Benefits and Executive Compensation or Health Care Groups with whom you work.
For more information, in the Tax Management Portfolios, see Cowart, 389 T.M., Medical Plans — COBRA, HIPAA, HRAs, HSAs and Disability, and in Tax Practice Series, see ¶5920, Health & Disability Plans.
Copyright © 2015 by Ballard Spahr LLP.
(No claim to original U.S. government material.)
All Bloomberg BNA treatises are available on standing order, which ensures you will always receive the most current edition of the book or supplement of the title you have ordered from Bloomberg BNA’s book division. As soon as a new supplement or edition is published (usually annually) for a title you’ve previously purchased and requested to be placed on standing order, we’ll ship it to you to review for 30 days without any obligation. During this period, you can either (a) honor the invoice and receive a 5% discount (in addition to any other discounts you may qualify for) off the then-current price of the update, plus shipping and handling or (b) return the book(s), in which case, your invoice will be cancelled upon receipt of the book(s). Call us for a prepaid UPS label for your return. It’s as simple and easy as that. Most importantly, standing orders mean you will never have to worry about the timeliness of the information you’re relying on. And, you may discontinue standing orders at any time by contacting us at 1.800.960.1220 or by sending an email to email@example.com.
Put me on standing order at a 5% discount off list price of all future updates, in addition to any other discounts I may quality for. (Returnable within 30 days.)
Notify me when updates are available (No standing order will be created).
This Bloomberg BNA report is available on standing order, which ensures you will all receive the latest edition. This report is updated annually and we will send you the latest edition once it has been published. By signing up for standing order you will never have to worry about the timeliness of the information you need. And, you may discontinue standing orders at any time by contacting us at 1.800.372.1033, option 5, or by sending us an email to firstname.lastname@example.org.
Put me on standing order
Notify me when new releases are available (no standing order will be created)