Cadillac Tax Reporting

Effective January 1, 2018, Health Care Reform imposes a 40% non-deductible excise tax on high cost health plans (sometimes called the “Cadillac Tax”). The Cadillac Tax is imposed on the excess value which is the amount by which the value of the health coverage exceeds specified threshold amounts. Plan sponsors will be required to calculate and report the amount of the excise tax, if any, that is owed with regard to their health plans. Although the excise tax generally will be paid by insurers and/or third party administrators, the amount of the tax is expected to be passed through to the employer sponsoring the high-cost plan (or plans).

If employers are found to be underreporting the cost of their health plans, the IRS has the authority to impose a penalty equal to the tax not paid, plus interest.

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Cadillac Tax Reporting Hot Topics and FAQs

  • If I don’t sponsor any plans that are subject to the Cadillac Tax, will I have to file a report?
    Answer: Probably not. An employer is only subject to the Cadillac Tax if the employer offers health plans that are included when calculating whether an employee’s coverage has exceeded the applicable threshold. If an employer does not offer such coverage, the employer will probably not have to submit anything to the IRS. Future agency guidance is likely to establish rules for who is required to submit a report.
  • If I sponsor coverage that’s subject to the Cadillac Tax but my coverage will not exceed the thresholds for any employee for the year, do I still have to submit a report?
    Answer: The current Health Care Reform rules do not include an answer for that question. Many employers are hoping for a safe harbor plan design that will exempt them from having to perform the calculation or report information to the IRS. Future agency guidance is likely to establish the reporting rules.
  • Which health coverage is subject to the Cadillac Tax?
    • The following benefits are subject to the Cadillac Tax: major medical (including retiree medical), prescription drug, Health FSAs, HRAs, HSAs (to the extent contributions are made by the employer, or made by the employee via pre-tax salary deferral), gap coverage, and, if purchased on a pre-tax basis, specified disease, hospital indemnity, and other fixed indemnity insurance. Certain wellness benefits or on-site clinics may also be subject to the Cadillac Tax if they are considered group health plans.
    • The following benefits are not subject to the Cadillac Tax: stand alone dental, vision, long-term care, accident, and disability coverage.

American Fidelity Assurance Company does not provide tax or legal advice.


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