Leanne Reagan

Leanne Reagan

Leanne Reagan‘s practice focuses on the design and implementation of qualified and non-qualified retirement and deferred compensation plans, welfare plans, cafeteria plans and other employee benefit programs for both public and private companies. She also helps clients maintain compliance with the federal laws and regulations associated with these plans, including ERISA, the Internal Revenue Code, federal healthcare reform, COBRA, and HIPAA. In addition, Leanne advises clients with respect to Section 409A compliance, negotiating and documenting executive employment agreements, equity arrangements, change-in-control agreements and severance agreements.

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House Republican Health Care Bill: Good News for Health Insurance Executives

An Affordable Care Act (ACA) provision that is often-overlooked by the media, but has impacted the ability of insurers and their non-insurance related entities, in their role as employers, to take tax deductions for certain compensation paid to their highly paid employees may be ending at the end of the year. If passed, the House Republican’s health care bill repealing … Continue Reading

Accountable Care, Non-Profit Status and the Dangerous Ripple Effect it May Cause

On April 8, 2016, the Internal Revenue Service (IRS) released Private Letter Ruling (PLR) 201615022, which denied tax-exempt 501(c)(3) status to a commercial accountable care organization (ACO). This ruling marks the first time the IRS published any guidance regarding commercial ACOs. The last guidance from the IRS regarding ACOs came in 2011 and was related to ACO participation in … Continue Reading

ACA Issues for Employers to Stay Aware of in 2015

With the Affordable Care Act’s Employer Mandate (Pay-or-Play penalties) now officially in effect, employers with 50 or more full-time or full-time-equivalent employees should have already made all significant changes to their benefit programs necessary to ensure that they offer “minimum essential” and “affordable” coverage to their full-time employees to avoid penalties in 2015. However, there are several ongoing ACA issues … Continue Reading

Federal Appeals Court in D.C. Strikes Down Key Aspect of Health Care Reform (Just Before the 4th Circuit’s Opposite Ruling) – Any Impact on the Individual and Employer Mandates?

Yesterday, the U.S. Court of Appeals for the District of Columbia Circuit, in a 2-1 ruling by a three judge panel, invalidated an Internal Revenue Service regulation that interpreted section 36B of the Affordable Care Act (“ACA”) as authorizing premium tax credits for insurance purchased on either a state or federally-facilitated Exchange. In striking down the IRS regulation, the majority … Continue Reading

ACA Cap on Deductibility of Compensation to Health Insurance Carriers’ Executives May Have Broad Tax Impacts

Health insurance carriers are keenly aware of many provisions of the Patient Protection and Affordable Care Act (“ACA”). But an often-overlooked ACA provision may actually impact the ability of these insurers and their non-insurance related entities, in their role as sophisticated employers, to take tax deductions for certain compensation paid to their executives.  This change results from the addition of … Continue Reading

Employers Receive Sample Exchange Notice and Face October 1 Deadline to Send to Employees

Employers have long been anticipating sample notices from the Department of Labor (“DOL”) that are required under the Affordable Care Act, informing employees (i) of the existence of the health care exchange (“Exchange”) and certain information about the services provided through the Exchange; (ii) of the possibility that in certain circumstances the employee may be eligible for a premium tax … Continue Reading

Departments Release Proposed Regulations on ACA’s 90-Day Waiting Period Limit

The Affordable Care Act (“ACA”) generally limits the maximum length of employer-sponsored group health plans’ waiting periods to no more than 90-days in 2014.  In the March 21, 2013 Federal Register, the U.S. Department of Labor, Health and Human Services , and the Internal Revenue Service jointly released proposed regulations to provide guidance to employers on how to implement this … Continue Reading

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