In mid-July, the IRS issued guidance, Notice 2013-45, on the one-year delay of the Affordable Care Act’s employer mandate, announced in a U.S. government blog earlier in the month. First and foremost, the guidance made the delay official, but what’s more, it defines what the delay doesn’t change, and, in many cases, leaves unclear.
“It made it very clear that the transition relief for the extension only applies for purposes on these reporting forms and has no effect on anything else,” says Paul Hamburger with Proskauer. “At this point, it is only the application of the fees for the mandate, and the reporting of the information on those forms.”
