On Feb. 23, 2015, the IRS issued Notice 2015-16 to begin the process of developing guidance to implement the Cadillac tax. Proposed or final regulations have not yet been issued. The attached Health Care Reform Bulletin provides an overview of Notice 2015-16, which describes potential approaches with regard to a number of issues under the Cadillac tax and invites comments on these approaches.

IRS Invites Comments on Cadillac Tax Implementation for 2018