IRS Issues Notice 2015-52 on Cadillac Tax Implementation
On July 30, 2015, the IRS issued Notice 2015-52 to continue the process of developing guidance to implement the Cadillac tax. Notice 2015-52 addresses additional issues under the Cadillac tax, including who is liable, employer aggregation and notice and payment of the tax. Proposed or final regulations have not been issued. The attached Health Care Reform Bulletin provides an overview of Notice 2015-52.