Notice 2015-52 (October 1, 2015)

Health Care

From the Church Alliance to the Internal Revenue Service (IRS), in response to Notice 2015-52, which solicited additional comments in preparation for proposed regulations to be issued concerning the “Cadillac Tax” on high cost employer-sponsored health coverage. The letter again requests relief from the tax, and flexibility to the extent relief is not granted. The letter notes the difficulty in calculating the cost of coverage for a church employer, and points out the challenges that would be involved in calculating and allocating any excess benefit in the time period suggested by the IRS.