Internal Revenue Bulletin: 2014-48
November 24, 2014
Group Health Plans that Fail to Cover In-Patient Hospitalization Services. The IRS, the Treasury Department, and the Department of Health and Human Services plan to publish proposed regulations providing that employer-sponsored health plans that fail to provide substantial coverage for in-patient hospitalization or physician services do not provide minimum value within the meaning of Code § 36B. Employers offering these plans should exercise caution in relying on the Minimum Value Calculator for any portion of a taxable year after publication of final regulations to demonstrate that the plans provide minimum value.
Final regulations clarify the regulations under section 312 regarding the allocation of earnings and profits in tax-free transfers from one corporation to another and modify the definition of an acquiring corporation for purposes of section 381 with regard to certain acquisitions of assets.
These final regulations provide clarification regarding the determination of the basis of stock or securities in certain reorganizations where no stock or securities of the issuing corporation is issued and distributed in the transaction. These final regulations clarify that only a shareholder that owns actual shares in the issuing corporation in such a reorganization can designate the actual share of stock of the issuing corporation to which the basis, if any, of the stock or securities surrendered will attach.
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