On March 29, 2011, the Internal Revenue Service (“IRS”) released Notice 2011-28 which provides employers with additional guidance on reporting the cost of employer-sponsored group health plan coverage on an employee's Form W-2. Under health care reform (the “Affordable Care Act”), employers were originally required to report the cost of group health plan coverage on the 2011 W-2s (issued in January 2012). In a subsequent Notice, the IRS delayed this reporting requirement until the 2012 W-2s would be issued in 2013. Now with the issuance of Notice 2011-28, employers are not required to report the cost of health care coverage prior to January 2013. Further, until additional guidance is issued, the Notice indicates that an employer is not subject to the reporting requirement for any calendar year if the employer was required to file fewer than 250 W-2s for the proceeding calendar year. As a result, if an employer files fewer than 250 W-2s for calendar year 2011, the employer would not be subject to the reporting requirements.
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IRS provides more guidance on reporting health care costs on W-2s
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