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Employee Benefits Client Alert
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October 21, 2010
IRS Releases Guidance on W-2 Reporting Requirement

The Patient Protection and Affordable Care Act of 2010 ("PPACA") requires employers to report the aggregate cost of employer-sponsored group health plan coverage on Form W-2, Wage and Tax Statement ("Form W-2"), beginning in 2011.  However, on October 12, 2010, the Internal Revenue Service ("IRS") issued Notice 2010-69, which provided interim relief for employers by making the W-2 reporting requirement voluntary, rather than mandatory, in 2011.  Accordingly, employers who do not report the aggregate cost of any applicable employer-sponsored coverage on Form W-2 in 2011 will not be subject to any penalties.  The U.S. Department of Treasury (the "Department of Treasury") and the IRS have determined that this relief is appropriate to provide employers with additional time to make any necessary changes to their payroll systems or procedures in preparation for compliance with the PPACA reporting requirements.   


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