ERISA and Global Benefits

Cadillac Tax Delayed

December 28, 2015

The Global Compensation, Benefits & ERISA Practice Group

On December 18, 2015, Congress officially handed employers two healthcare holiday presents by delaying for two years the effective date of the so-called “Cadillac Tax” and by making the tax deductible. The new date the tax is scheduled to take effect is January 1, 2020. We note that the budget bill also requires the National Association of Insurance Commissioners to study and provide a report -- within the next 18 months -- concerning the "suitability" of the  current age and gender benchmarks that will be used to determine the applicable limits on the amount of tax imposed on each employer. We will keep tabs on efforts to fully repeal the tax.