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Implementing a new “Cadillac plan” tax on high-cost employer health coverage could lead to “mind-bending tax administration issues,” according to Mark Holloway.

Holloway, a benefits compliance law specialist at Lockton Companies, makes that prediction in an analysis of a new Internal Revenue Service (IRS) Cadillac plan request for information, in the IRS Notice 2015-52. In the notice, IRS officials ask for ideas about how to implement Internal Revenue Code (IRC) Section 4980I, the section of the tax law that gives the Cadillac plan tax rules.

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