October 7, 2016

A few days ago, the IRS released the final instructions for Forms 1094-C and 1095-C for 2016. The following is a review of those instructions along my comments and observations.

Click here for full PDF

Free Webinar Focused on Reviewing Form 1094-C for 2015

May 25, 2016

I  conducted a free webinar focused on reviewing Form 1094-C for 2015 before it has to be filed with the IRS on May 25, 2016.

  • The Webinar is 60 minutes in length.
  • Form 1094-C has to be filed with the IRS by May 31, 2016 for paper filings and June 30, 2016 for electronic filings.
  • This webinar reviewed every aspect of Form 1094-C. It also explained what sections have to be completed and ways to avoid common filing errors.
  • This Webinar included a substantial question and answer period.
  • This webinar is important for any employer or adviser who wants to be prepared for these requirements.

The webinar is presented by Larry Grudzien, Attorney at Law.


August 18, 2008

The Internal Revenue Service (IRS) released IRS Notices 2008-51 and 2008-52 on June 4, 2008. These notices clarify the changes made by the Tax Relief and Health Care Act of 2006 for rolling over IRA funds to an HSA and for the new annual HSA contribution limit.   The following will first review the rules and then explain what items have been clarified… Download the whole document here

IRS Releases Proposed Regulations under Code Sections 4980B, 4980D, 4980E and 4980G

August 17, 2008

The Internal Revenue Service (IRS) released proposed regulations under Internal Revenue Code (“Code”) Sections 4980B, 4980D, 4980E and 4980G on July 16, 2008. The proposed regulations include:

  • The form and due dates for reporting and paying excise taxes under Code Section 4980B (failure to comply with the Consolidated Omnibus Budget Reconciliation Act (COBRA) requirements), Code Section 4980D (failure to comply with the Health Insurance Portability and Accountability Act (HIPAA) requirements), Code Section 4980E (failure to make comparable Archer Medical Savings Account (MSA) contributions) and Code Section 4980G (failure to make comparable HSA contributions).
  • Calculating comparable HSA contributions.
  • Special rules for making employer contributions to HSAs for non-highly compensated employees (NHCEs).
  • Comparability Rules and Qualified HSA Distributions.

Rules for Reporting and Paying Excise Taxes
Code Section 4980B – Failure to Comply With the Consolidated Omnibus Budget Reconciliation Act (COBRA) Requirements
Excise Tax: Employers that violate COBRA may be subject to both civil sanctions and tax penalties. Under COBRA’s civil sanction procedures, either the Department of Labor or plan beneficiaries themselves can sue a plan that fails to provide…. Download the whole document here – hsa-proposed-regulations.pdf