Health Coverage Tax Credit (HCTC)

  • As of December 22, 2015, IRS Notice 2016-02 supersedes certain information in this blog entry.

On July 6, 2015, President Obama signed the Trade Preferences Extension Act of 2015.  Among other things, the Trade Act retroactively reinstated the Health Coverage Tax Credit (HCTC), which had previously expired on January 1, 2014, and extended its availability through December 31, 2019.  As discussed below, the reinstated HCTC may require employers to update COBRA notices and summary plan descriptions.  In addition, it may present a strategic planning opportunity in certain bankruptcy situations.