IRS Issues Notice 2015-52 on Cadillac Tax Implementation

For taxable years beginning in 2018, the Affordable Care Act (ACA) imposes a 40 percent excise tax on high-cost group health coverage. This tax, also known as the “Cadillac tax,” is intended to encourage companies to choose lower-cost health plans for their employees.

On July 30, 2015, the Internal Revenue Service (IRS) issued Notice 2015-52 to continue the process of developing guidance to implement the Cadillac tax. This notice supplements Notice 2015-16, issued on Feb. 23, 2015.

Notice 2015-52 addresses additional issues under the Cadillac tax, including:

• Identification of the taxpayers who may be liable for the excise tax;
• Employer aggregation;
• Allocation of the tax among the applicable taxpayers; and
• Payment of the applicable tax.

The IRS invites comments on these issues and any other issues under the Cadillac tax. Currently, proposed or final regulations have not been issued on the ACA’s Cadillac tax provision. After considering the comments on both notices, the IRS intends to issue proposed regulations under the Cadillac tax.

Comments should be submitted no later than Oct. 1, 2015. Read the full article for additional details

If you have any questions about this paper, or would like to talk to a trusted advisor, please contact Strategic Benefit Services for assistance by calling (855) 882-9177 or email us at

sbs@hanys.org.