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Health Care Reform For Small Employers (7 pp) (relevancy score: 100%)

by Kelly A. Means, Richard A. Naegele, William P. Prescott, and Mark P. Altieri
from the The Practical Tax Lawyer Vol. 25 No. 1

However, under the Small Business Tax Credit interim and final regulations for group health plans Eligible small employers will be provided a tax and health insurance coverage relating to status as credit for employer contributions made to purchase a grandfathered health plan under health care re- health insurance for their employees in tax years beginning in 2010 through 2013. Cafeteria Plans Under the new health care reform legislation, CONCLUSION · The health care reform legisla- for plan...

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State and Local Meets International (handout) (74 pp) (relevancy score: 100%)

by
from 21st Annual Philadelphia Tax Conference (October 26, 2010)

· In some U.S. treaties, sub-national taxes of the other country are "covered taxes" ­ Switzerland (`federal, cantonal and communal taxes on income")­ Iceland ("The income tax to the municipalities")­ Portugal ("local surtax on corporate income tax")· OECD model treaty: income and capital taxes "imposed on behalf of a Contracting State or of its political subdivisions or localauthorities". U.S. Model Treaty United States Model Income Tax Convention of November 15, 2006 (hereinafter "U.S. ...

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Tax Director Forum: What's Keeping Them Up at Night? (presentation slides) (handout) (12 pp) (relevancy score: 100%)

by Dennis Ross Diana L. Wollman Glen A. Kohl Richard D'Avino
from 21st Annual Philadelphia Tax Conference (October 26, 2010)

702 2 703 ABA 21st Annual Philadelphia Tax Conference October 27, 2010 Tax Director Forum: What's Keeping Them Up at Night? 2 704 Topics We Will Address · Schedule UTP· Transfer Pricing· Financial Statements v Cash· Settlements with Taxing Authorities· Penalties· Offshore Cash· Outside Advisors 3 Schedule UTP · Timing from start to finish ­ initially announced January 23, 2010 ­ finalized September 24, 2010 What is your view of the process and where we eventually landed? §1.66626 8 707 ...

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Current Developments--Philadelphia Tax Conference (presentation slides) (handout) (22 pp) (relevancy score: 100%)

by
from 21st Annual Philadelphia Tax Conference (October 26, 2010)

· A domestic series should be treated as a separate local law entity even if its business purpose, investment objective, or ownership overlaps with that of other series or the series organization. 27 Ownership of Series and Assets · Ownership of series and assets of series determined under general tax principles. · Uncertain federal CTB issues where: ­ Core/series organization defaults to corporation treatment, but cells/series elect flow through treatment; or ­ Cells/series elect to be ...

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How to Account for Distressed Debt (presentation slides) (16 pp) (relevancy score: 100%)

by David C. Garlock Jeffrey Maddrey Steven M. Rosenthal
from 21st Annual Philadelphia Tax Conference (October 26, 2010)

­ Open transaction treatment for speculative investments · Section 1272(a)(6) · Bad debt rules and rules governing losses on debt securities. ­ Accrue or don't accrue interest income ­ Apply or don't apply market discount rules · Would a three-tier system make more sense, with ­ Top tier, full accrual ­ Middle tier, accrual based on expected collections ­ Lowest tier, open transaction accounting? 12 9 Bad Debt Losses Overview · Section 166(a) allows ordinary losses for bad debts in certain ...

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Selected Dollar and Cents Issues for Qualified Retirement Plans (presentation slides) (14 pp) (relevancy score: 100%)

by Russell Hall
from 21st Annual Philadelphia Tax Conference (October 26, 2010)

P c ra la p d d lia la in e e a lu rtic n re rv a s ms o re e te p c p l p s a e la B p a d th u o ts re in n h tru re d s n tic l p to irc ms ll rig s n ts ­ D la ta n c ility m e . P c d s ra rio f th de tio e e e e rv tio fa o es a p ra ye e p e ts re iz rm d c h tru e n lo "o e n ll rig s p a rfo e t th d . , b tio e B p t ju la tio r fa n n ts th .

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IRS 'Payroll Tax' Developments: Impact on Fringe Benefits, Executive Compensation, Worker Classification and Downsizing Payments (presentation slides) (28 pp) (relevancy score: 100%)

by David R. Fuller
from 21st Annual Philadelphia Tax Conference (October 26, 2010)

42 21 54 IRS Administrative Definition Revenue Ruling 80-124:· The IRS again discards the use of the term "supplemental unemployment benefits" and adopts the statutory term "supplemental unemployment compensation benefits". He is recognized as an authority on matters involving payroll taxes, including worker classification, Section 530 relief, Section 3121(v), social security taxes, independent contractors, income tax withholding, supplemental unemployment compensation benefit plans (SUB pay...

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Towers Watson Memo RE: PBGC Proposed Rule Clarifies Many 4062(e) Issues (18 pp) (relevancy score: 100%)

from 21st Annual Philadelphia Tax Conference (October 26, 2010)

Only single-employer plans which are not multiple employer plans are covered by the proposed regulation. Under the proposed regulations, section 4062(e) would also apply to an employer's cessation of an operation at a facility even if the operation is continued or resumed by another employer at the same or another facility. An employee's separation from employment may result from an employer's cessation of an operation at a facility even if the employee is employed in a different operation ...

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Towers Watson Memo RE: Legislation to Facilitate Roth Conversions Headed to Final Passage (6 pp) (relevancy score: 100%)

from 21st Annual Philadelphia Tax Conference (October 26, 2010)

General Discussion and Observations: In-plan Roth ConversionsIn general, 401(k), 403(b) and (once available) governmental section 457 plans that include designated Roth accounts could permit in-plan conversions of distributions to an employee (or a surviving spouse) of amounts distributed from an account under the plan that is not a designated Roth account into a designated Roth account. Once governmental Roth plans take effect, this in-plan conversion option would be available to the plan's...

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PPACA Processes for Internal Claims and Appeals, External Review Requirements (Towers Watson Bulletin) (6 pp) (relevancy score: 100%)

from 21st Annual Philadelphia Tax Conference (October 26, 2010)

84 2 85 New Regulations: PPACA Processes for Internal Claims and Appeals, External Review Requirements Bulletin On July 23, 2010, the IRS, DOL and HHS published interim final regulations under the Patient Protection and Affordable Care Act (PPACA) regarding processes for internal claims and appeals, as well as external review processes, for insured and self-insured, non-grandfathered group health plans. However, the federal external review process is not available for towerswatson.com New ...

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Additional Guidance Issued on PPACA External Review Process; Related Model Notices Also Released (Towers Watson Bulletin) (6 pp) (relevancy score: 100%)

from 21st Annual Philadelphia Tax Conference (October 26, 2010)

These processes apply to non-grandfathered, ERISA- necessary for plans to implement a compliant federal covered self-insured group health plans (and certain external review process. insured group health plans that are not subject to a state external review process, and therefore are This interim enforcement safe harbor applies for plan subject to the federal external review process. towerswatson.com Additional Guidance Issued on PPACA External Review Process; Related Model Notices Also ...

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HHS Issues Guidance for Limited Benefit or Mini-Med Plan Waivers From the Restricted Annual Dollar Limits (Towers Watson Bulletin) (4 pp) (relevancy score: 100%)

from 21st Annual Philadelphia Tax Conference (October 26, 2010)

96 2 97 Health Care Reform HHS Issues Guidance for Limited Benefi t or Mini-Med Plan Waivers From the Restricted Annual Dollar Limits Bulletin September 7, 2010 The Department of Health and Human Services (HHS) has released a memorandum (HHS OCIIO 2010-1) addressing limited benefi t plans (also known as "mini-med" plans) and the process for obtaining waiversfrom the annual dollar limit requirements under the Patient Protection and Aff ordable Care Act (PPACA). The waiver restricted annual ...

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IRS Issues Guidance on Reimbursement of OTC Medicines and Drugs From Health FSAs, HRAs, HSAs and Archer MSAs (Towers Watson Bulletin) (6 pp) (relevancy score: 100%)

from 21st Annual Philadelphia Tax Conference (October 26, 2010)

100 2 101 Health Care Reform IRS Issues Guidance on Reimbursement of OTC Medicines and Drugs From Health FSAs, HRAs, HSAs and Archer MSAs Bulletin September 7, 2010 The Internal Revenue Service (IRS) has released guidance (Notice 2010-59) and some related questions and answers (Q&As) regarding the reimbursement of over-the-counter (OTC) medicines and drugs from group health plans, health fl exible spending accounts (health FSAs), health reimbursement accounts (HRAs), health savings ...

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IRS Provides Interim Relief on Form W-2 for 2011 (Towers Watson Bulletin) (4 pp) (relevancy score: 100%)

from 21st Annual Philadelphia Tax Conference (October 26, 2010)

106 2 107 Health Care Reform IRS Provides Interim Relief on Form W-2 for 2011 Bulletin October 13, 2010 The Internal Revenue Service (IRS) provided employers with one year of relief from reporting the cost of coverage under an employer-sponsored group health plan on Form W-2, Wage and Tax Statement. Notice 2010-69 provides that reporting the aggregate cost of employer-sponsored coverage on Form W-2, as required under the Patient Protection and Aff ordable Care Act (PPACA), will be optional ...

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PPACA Guidance Issued Eliminating HIPAA Opt-Out Election for Self-Insured Nonfederal Governmental Plans (Towers Watson Bulletin) (4 pp) (relevancy score: 100%)

from 21st Annual Philadelphia Tax Conference (October 26, 2010)

110 2 111 Health Care Reform PPACA Guidance Issued Eliminating HIPAA Opt-Out Election for Self-Insured Nonfederal Governmental Plans Bulletin September 28, 2010 The Department of Health and Human Services (HHS) has addressed amendments by the Patient Protection and Aff ordable Care Act (PPACA) to the law permitting self-funded nonfederal governmental plans to opt out of compliance with certain federal benefi t mandates. HHS issued a memo explaining the impact of the PPACA amendment ...

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HHS Announces New ERRP Website, Provides List of Approved Applicants and Updates FAQs (Towers Watson Bulletin) (4 pp) (relevancy score: 100%)

from 21st Annual Philadelphia Tax Conference (October 26, 2010)

114 2 115 Health Care Reform HHS Announces New ERRP Website, Provides List of Approved Applicants and Updates FAQs Bulletin September 1, 2010 On August 31, 2010, the Department of Health and Human Services (HHS) launched the fi rst phase of the ERRP Secure Website, which is to be used as part of ongoing implementation of the Early Retiree Reinsurance Program (ERRP). HHS also announced the fi rst round of nearly 2,000 ERRP Secure Website ERRP applications that have been approved and has ...

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Supplemental Guidance Issued on Several Topics to Clarify PPACA Compliance (Towers Watson Bulletin) (6 pp) (relevancy score: 100%)

from 21st Annual Philadelphia Tax Conference (October 26, 2010)

If these steps are taken, an otherwise grand- · DOL Technical Release 2010-02 on Interim fathered insured group health plan will continue to be Procedures for Claims and Appeals considered grandfathered. The grace period conditions under which a grandfathered group health applies only for certain new content required under plan may change carriers without losing grandfathered interim fi nal claims and appeals regulations, such status. Grandfathered plans need not comply with the new claim ...

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HHS Issues Statements Acknowledging Special Circumstances Involving Mini-Med Plans and the PPACA’s Medical Loss Ratio Standards, and Awards Money to States for the Establishment of Exchanges (Towers Watson Bulletin) (4 pp) (relevancy score: 100%)

from 21st Annual Philadelphia Tax Conference (October 26, 2010)

124 2 125 Health Care Reform HHS Issues Statements Acknowledging Special Circumstances Involving Mini-Med Plans and the PPACA's Medical Loss Ratio Standards, and Awards Money to States for the Establishment of Exchanges Bulletin October 4, 2010 On September 30, 2010, the Department of Health and Human Services (HHS) released a statement addressing the application of medical loss ratio (MLR) standards imposed by the Patient Protection and Aff ordable Care Act (PPACA) to certain health plans, ...

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Interim Final Regulations Issued on Preventive Services Under PPACA (Towers Watson Bulletin) (4 pp) (relevancy score: 100%)

from 21st Annual Philadelphia Tax Conference (October 26, 2010)

128 2 129 Health Care Reform Bulletin Interim Final Regulations Issued on Preventive Services Under PPACA July 15, 2010 On July 14, the Internal Revenue Service (IRS), the Departments of Labor (DOL) and Health and Human Services (HHS) released interim final rules addressing the preventive services that must be covered by a group health plan or insurer under the Patient Protection and Affordable Care Act (PPACA). · Plans are free to cover preventive services that go beyond the government's ...

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Corporate Taxation: Planning Considerations and Updates (60 pp) (relevancy score: 100%)

by
from 21st Annual Philadelphia Tax Conference (October 26, 2010)

Split equ Ø Ø Exec Plann Ø Ø Ø Ø Ø Ø 139 7 d Interest ieCarr lication to corporate joint ventures App 140 8 ing y" ney PI) pend ic "carr e class CIs) slation is th other people's mo anaging als ly beyond partnerships pital Interests (Q re: ire m ividu stries lication results from: ent Services Partnership Interest (IS alified Interests ould app all indu exception for Far-reaching legi structu ualified Ca isquD oes not requ ot just to ind Investm Q D N Corporations and Across arrow Ø siness ...

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