The IRS Office of Chief Counsel recently issued a memorandum (https://www.irs.gov/pub/irs-lafa/20200801f.pdf) that responded with a resounding “No” to the question of whether an employer shared responsibility payment (ESRP) imposed under Internal Revenue Code §4980H is subject to any statute of limitations on assessment.
Author: Karen Gelula
Karen Gelula counsels public and private companies across industry sectors on all types of employee benefits and executive compensation matters. She advises clients on the design, operation, governance and compliance of qualified retirement plans, and seeks to ensure that employers’ health and welfare benefits plans comply with all applicable federal and state laws, and associated regulations.