Internal Revenue Bulletin: 2013-51
December 16, 2013
This revenue ruling holds that a covered entity must include in gross income amounts it collects from policyholders to offset the cost of the fee imposed under § 9010 of the Affordable Care Act.
Section 1411 imposes a 3.8 percent tax on certain individuals, estates, and trusts (the “Net Investment Income Tax”). The tax is imposed on the lesser of the taxpayer’s (A) Net Investment Income for such taxable year, or (B) the excess of taxpayer adjusted gross income over certain statutorily defined threshold amounts. The regulations provide guidance on the general application of the Net Investment Income Tax to individuals, estates, and trusts, and the computation of Net Investment Income.
These regulations provide guidance on the computation of net investment income under section 1411 of the Code. The regulations affect individuals, estates, and trusts whose incomes meet certain income thresholds. Comments on this proposed rule are requested by March 3, 2014.
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