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IRS Issues Guidance for Changes in Measurement Periods or Methods Applicable to an Employee

In Notice 2014-49, the IRS provided guidance for determining if an employee is a full-time employee for purposes of the Affordable Care Act in situations where the measurement period applicable to the employee changes. The change may occur because the employee transfers from a position in which one measurement period applies to a position in which a different measurement period applies within the same large employer. The Notice also provides guidance in the event of corporate transactions such as mergers and acquisitions in which the employers use different measurement periods. Treasury and the IRS anticipate issuing further guidance. Taxpayers may rely on the Notice until such guidance is issued, and in any case, through the end of calendar year 2016.  A copy of IRS Notice 2014-49 can be found here.

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