How Does the Affordable Care Act Affect You and Your Taxes?

The health care legislation, the Affordable Care Act (aka Obamacare), signed into law in 2010 affects virtually every individual in one way or another and  significantly impacts the preparation of tax returns. The provisions take effect over a period of years and are categorized in this article by the year they became or will become effective. Some of the provisions include additional taxes to offset the cost of the health care benefits included in the legislation for lower-income individuals. 

The following is an overview of the provisions that apply to individual taxpayers and small businesses.

2009
  • Student Loan Forgiveness for Health Professionals – Excludes student loan debt forgiveness from income for certain medical professionals who work in health professional shortage areas.
2010
  • Tanning Services Excise Tax – A 10% excise tax is imposed on the amount paid for any indoor tanning service.

  • Excludable Medical Reimbursements for Older Children – An income exclusion for reimbursements of medical care expenses by an employer-provided accident or health plan is extended to any child of an employee who hasn't attained age 27.

  • Self-Employed Health Insurance Deduction – Self-employed individuals may include children who have not attained age 27 in their tax-deductible health insurance. 

  • Tax Credits for Small Employers Offering Health Coverage – Provides a tax credit for an eligible small employer for non-elective contributions to purchase health insurance for its employees.
2011
  • Increased Tax on Nonqualifying HSA or Archer MSA Distributions – The additional tax for making non-medical withdrawals from Health Savings Plans and Archer MSA plans is increased to 20%.
     
  • Over-the-Counter Medication Restriction for Employer Plans – Over-the-counter medications no longer qualify for reimbursement.

  • Small Employer Simple Cafeteria Plans – Small employers may provide employees with a "simple cafeteria plan."
2012
  • Employer W-2 Reporting Responsibilities – Employers are required to disclose the aggregate cost of employer-sponsored health coverage to their employees on Form W-2 (for information purposes only). An exception applies for employers who were required to file fewer than 250 Forms W-2 for the preceding calendar year.
2013
  • Additional Medicare (Hospital Insurance) Tax for High-Income Taxpayers – The Medicare (Hospital Insurance) tax rate (currently at 1.45%) is increased by 0.9 percentage points on incomes over a threshold. Applies to employees and self-employed individuals.

  • Surtax on Net Investment Income for High-Income Taxpayers – A 3.8% surtax is imposed on net investment income of high-income individuals, estates, and trusts if their modified adjusted gross income exceeds a threshold amount.

  • Employer Health FLEX-Spending Plan Contributions Limited – Contributions to health flexible spending plans is limited to $2,500 (adjusted annually for inflation).

  • Medical Itemized Deductions Limited – The AGI threshold percentage for claiming itemized medical expenses is increased from 7.5% to 10%, except remains 7.5% through 2016 for taxpayers age 65 or older. 

  • Compensation Deduction Limit for Health Insurance Issuers – Limits companies' deduction for certain employees' compensation.

  • Fee on Self-Insured Health Plans (Patient-Centered Outcomes Research Fee) – a fee equal to $2 ($1 for plan years ending during physical year 2013) multiplied by the average number of lives covered under the plan. The fee amount is adjusted annually based on the percentage increase in the projected per capita amount of the National Health Expenditures published by Health and Human Services.

  • Employee Notices – Beginning January 1, 2014 (October 1, 2013 for existing employees), certain employers must provide written notice to employees about health insurance coverage options available through the Marketplace (insurance exchanges).
2014
  • Mandatory Heath Insurance Overview – Many of the provisions of the health care legislation are linked to the mandate that everyone becomes insured. The chart provides an overview of how these provisions interact to achieve that goal.

  • American Health Benefit Exchanges – By 2014, each state  was to establish an exchange (Marketplace) to help individuals and small employers obtain coverage. Because many states chose not to do so, the federal government established a federal Marketplace for these individuals to use.  

  • Penalty For Not Being Insured – Non-exempt U.S. citizens and legal resident taxpayers will be penalized for failing to maintain at the least the minimum essential health coverage, unless the individual qualifies for an exemption specified in the law or meets the criterion for a hardship exemption. 

  • Premium Tax Credit – Tax credits will be available for low-income individuals who obtain health insurance coverage with a qualified health plan (QHP) through an “Exchange.” The credit may be taken on the individual’s income tax return or in advance as a subsidy to help pay for the insurance premiums with the actual credit and any advances reconciled on the individual’s Form 1040.
2015
  • Large Employer Health Coverage Excise Tax – This penalty was originally scheduled to become effective in 2014 but was delayed until 2015. Large employers (50 employees or more) would be required to pay a penalty if any of its full-time employees were certified to the employer as having purchased health insurance through a state exchange and qualified for either tax credits or a cost-sharing subsidy. (Penalty is delayed until 2016 for employers with 50 to 99 employees who meet certain conditions.) 
     
  • Mandatory Insurer and Employer Reporting - Health insurers are required to file information returns reporting each individual for whom minimum essential coverage is provided.  In addition, each employer is also required to provide information related to each employee covered under the employer’s plan.   
2018
  • Excise Tax on High-Cost Employer-Sponsored Health Coverage – There will be a 40% nondeductible excise tax on insurance companies and plan administrators for any health coverage plan where the premiums exceed certain limits.

Student Loan Forgiveness for Health Professionals

Previously, an individual's gross income didn't include cancellation of debt income that was attributable to the discharge of all or part of any student loan if the discharge was made under a provision of the loan - that all or part of the indebtedness would be discharged if the individual worked for a certain period of time in certain professions for any of a broad class of employers.

New Law: The law has been amended to include amounts received by an individual in tax years beginning after Dec. 31, 2008; the gross income exclusion for amounts received under the National Health Service Corps loan repayment program or certain State loan repayment programs is modified to include any amount received by an individual under any State loan repayment or loan forgiveness program that is intended to provide for the increased availability of health care services in underserved or health professional shortage areas as determined by the State.


Employer Tax-Free Medical Benefits Available to Children under Age 27

Health coverage provided for an employee's children under 27 years of age is generally tax-free to the employee. 

Child – Broad Definition for this Purpose

Other than age, the “child” definition has no other restriction.  Thus, there are no income or marital restrictions. For this purpose, a child includes a son, daughter, stepchild, adopted child or eligible foster child.


This provision allows employers with cafeteria plans – plans that allow employees to choose from a menu of tax-free benefit options and cash or taxable benefits – to permit employees to make pre-tax contributions to pay for this expanded benefit. 

The definition of “child” for this purpose includes the individual’s:
  • child,
  • stepchild,
  • legally-adopted individual, 
  • an individual lawfully placed with the employee for legal adoption, and 
  • an eligible foster child.   

No other requirements apply so long as the individual meets the definition of a child and has not reached age 27 by the last day of the year. Even a married child is included by this definition! (But the married child’s spouse and/or children are not covered.) A child attains age 27 on the 27th anniversary of the date the child was born (for example, a child born on April 10, 1989 attained age 27 on April 10, 2016).

Contact your employer for further information regarding the employer’s plan related to this very beneficial provision.

Increased Tax on Nonqualifying HSA or Archer MSA Distributions

The additional tax for HSA withdrawals for other than qualified medical expenses before age 65 is increased from 10% to 20%, and the additional tax for Archer MSA withdrawals for other than qualified medical expenses is increased from 15% to 20%.  Distributions after age 65 are not subject to the penalty.

Small Employer Simple Cafeteria Plans

Small employers (average of 100 or fewer employees on business days during either of the two preceding years) may provide employees with a "simple cafeteria plan." Under such a plan, the employer is provided with a safe harbor from the nondiscrimination requirements for cafeteria plans as well as from the nondiscrimination requirements for specified qualified benefits offered under a cafeteria plan–

o including group term life insurance,
o benefits under a self-insured medical expense reimbursement plan, and
o benefits under a dependent care assistance program.
 
Note: Once the Simple Cafeteria plans have been established, the employer is deemed as having met the small employer requirement until such time as the average number of employees exceeds 200 on business days during any year proceeding any such subsequent year.

Simple Cafeteria Plan – For purposes of the provision, a simple cafeteria plan is a plan that:

(1) is established and maintained by an eligible employer,

(2) meets prescribed contribution requirements, and

(3) meets prescribed eligibility and participation requirements. 

Contribution Requirements – To create a simple cafeteria plan, the employer will have to make contributions to provide qualified benefits under the plan on behalf of each qualified employee (without regard to whether a qualified employee makes any salary reduction contribution) in an amount equal to:

(1) a uniform percentage (not less than 2%) of the employee's compensation for the plan year, or

(2) an amount which is not less than the lesser of
(a) 6% of the employee's compensation for the plan year, or
(b) twice the amount of the salary reduction contributions of each qualified employee.

The requirements of (2) above are not met if, under the plan, the rate of contributions with respect to any salary reduction contribution of a highly compensated or key employee at any rate of contribution is greater than that with respect to an employee who is not a highly compensated or key employee.

Qualified Employee – Does not include highly compensated or key employees.

Highly-Compensated Employee – Is any employee who:

(1) was a five percent owner at any time during the year or the preceding year or,

(2) for the preceding year, received compensation from the employer in excess of the inflation adjusted compensation amount of $80,000 ($120,000 for 2015), and, if the employer elects, was in the top-paid group of employees for the preceding year.  The employer can make the election annually, without the consent of IRS.  An employee is in the top-paid group of employees for any year if such employee is in the group consisting of the top 20 percent of the employees when ranked on the basis of compensation paid during such year.

Key Employee - In general, the term “key employee” (Sec 416(i)) for 2015 (call for other years) means an employee who, at any time during the plan year, is an officer of the employer having an annual compensation greater than $170,000 or a 5-percent owner of the employer, or a 1-percent owner of the employer having an annual compensation from the employer of more than $150,000.

Minimum Eligibility & Participation Requirements - The minimum eligibility and participation requirements will be met with respect to any year if, under the plan,

(a) all employees who have at least 1,000 hours of service for the preceding plan year are eligible to participate, and

(b) each employee eligible to participate in the plan may, subject to terms and conditions applicable to all participants, elect any benefit available under the plan.

However, an employer will be able to elect to exclude under the plan, employees:

(1) who have not attained the age of 21 before the close of a plan year (plan may provide for a younger age),

(2) who have less than one year of service with the employer as of any day during the plan year (plan may provide for a shorter period of service),

(3) who are covered under an agreement which the Secretary of Labor finds to be a collective bargaining agreement, if there is evidence that the benefits covered under the cafeteria plan were the subject of good faith bargaining between employee representatives and the employer, or

(4) who are described in Code Sec. 410(b)(3)(C) (relating to nonresident aliens working outside the U.S.)

If you would like to explore the benefits of setting up a simple cafeteria plan for your company, please give this office a call.

Additional Medicare (Hospital Insurance) Tax - High-Income Taxpayers

The Medicare (aka Hospital Insurance (HI)), tax rate (currently at 1.45%) would be increased by 0.9 percentage points on individual taxpayer earnings (wage withholding and SE tax) in excess of compensation thresholds for the taxpayer’s filing status; see table below. These amounts are not adjusted for inflation, so will remain as shown until changed by Congress.

Wage Withholding – Thus, the wage withholding Medicare rate would be 1.45% up to the income threshold and would be 2.35% (1.45 + 0.9) on amounts in excess of the threshold.

SE Tax – The SE tax rate would be 2.9% up to the income threshold and would be 3.8% (2.9 + 0.9) on amounts in excess of the threshold. 

All Income Combined for Purposes of the Threshold

For purposes of determining the additional Medicare tax, all wage and self-employment income is combined.  For married taxpayers, the spouses’ wages and self-employment incomes are combined. 




Wages – The following details pertain to wage withholding:

o An employer must withhold the additional Medicare tax based upon the wages the employee receives from the employer. 

o If the spouse works for the same employer, the employer may disregard the amount of wages received by the employee's spouse when computing the withholding for either spouse.
 
o Where a taxpayer has multiple employment, or self-employment and/or the spouse also works, the taxpayer is responsible for the additional 0.9% tax to the extent it is not withheld by an employer and will pay the additional amount on their 1040.

o The employer will not be liable for any additional 0.9% Medicare tax that it fails to withhold and that the employee later pays, but will be liable for any penalties resulting from its failure to withhold.

No Additional Tax Imposed on Employers

The entire 0.9% additional Medicare tax is the responsibility of the individual taxpayer and the employer is not required to make a matching contribution.

Self-Employment Income – The following details pertain to payment of the additional Medicare SE tax:

o The self-employed taxpayer will be responsible for the additional 0.9% Medicare tax.  And like an employer will not be liable for the matching amount. 

o The SE tax computation deduction continues to be computed using half the sum of the OASDI (Social Security) tax rate and only the regular Medicare tax rate (i.e., 7.65%), without regard to the additional 0.9% Medicare tax. 
 
Reporting Mechanics (Form) – As part of the taxpayer’s Form 1040 filing, the additional Medicare tax is computed on Form 8959 and then that tax and the additional withholding are reconciled to see if the taxpayer owes more tax or is eligible for a credit of excess withholding.

Example – Multiple Employers – Hal has two employers, one of which pays him an annual salary and bonus of $175,000 and the other pays him $75,000.  Hal’s wife, Patricia, has wages of $50,000.  Their combined wage total is $300,000 but no one employer paid them more than $250,000.  Thus, none of their employers withheld any additional Medicare tax, so Hal and Patricia will be responsible for the additional $450 (0.9% of ($300,000 - $250,000)) of Medicare tax when they file their 1040.

Medical Itemized Deductions Limited

The itemized deduction for medical expenses are limited in the following manner:

AGI Threshold - The AGI threshold percentage for claiming medical expenses on a taxpayer’s Schedule A is increased from 7.5% to 10%, which is the same as the current threshold percentage for alternative minimum tax (AMT) purposes.  

Delayed Implementation for Seniors - Individuals (and their spouses) age 65 (before close of year) and older will continue to use the 7.5% rate though 2016.

AMT & Regular Tax AGI Limit Become the Same

The Medical AGI Threshold for AMT is also 10%.  Thus, with the implementation of the 10% threshold for regular tax, there will no longer be a medical adjustment for AMT. However, through 2016, seniors with medical expenses who are subject to AMT will have an AMT medical adjustment.



$500,000 Compensation Deduction Limit for Health Insurance Issuers

For services performed during that year, a covered health insurance provider isn't allowed a compensation deduction for an “applicable individual” (officers, employees, directors, and other workers or service providers such as consultants) in excess of $500,000.

American Health Benefit Exchanges

Each state may establish an Insurance Exchange (more often termed the Marketplace) to help individuals and small employers that reside in their state obtain coverage. If a state fails to establish a Marketplace, its residents must use the Marketplace established by the federal government.  The primary purpose of the Marketplace is to provide a source for insurance meeting the requirements of the Affordable Care Act. 

Insurance can only be purchased through the Marketplaces during open enrollment periods, except certain life events and status changes (examples: marriage, birth or adoption of a child, divorce) can make people eligible for a Special Enrollment Period to enroll in or adjust health coverage through a Marketplace. For coverage in 2015, the open enrollment period is November 15, 2014 through February 15, 2015.

Benefit options will be in a standard format and a single enrollment form used for all policies.  Plans offered through the Marketplace must provide essential health benefits, limit cost sharing, and provide specified accrual benefits (i.e., the percentage amount paid the insurer).  

Plans in the individual and small group markets use a metallic designation for the accrual benefits provided:
  • Bronze 60%
  • Silver 70%
  • Gold 80%
  • Platinum 90%
Individuals who purchase health care policies through a Marketplace may be eligible for low-income premium subsidies, and/or a “premium tax credit.” The amount of the premium assistance is based on the taxpayer’s income as a percentage of the federal poverty guidelines.  The credit phases out between 100 and 400 percent of the poverty level based on family size.  Individuals should be sure to notify their Marketplace if their household income or family size changes during the year so that any advance premium tax credit can be adjusted accordingly. This will prevent an unexpected tax surprise when their income tax return for the year is completed.


Penalty for Not Being Insured

Non-exempt U.S. citizens and legal resident taxpayers will be penalized for failing to maintain at the least the minimum essential health coverage, which includes:

  • Government-sponsored programs (e.g., Medicare, Medicaid, Children's Health Insurance Program),
  • Eligible employer-sponsored plans,
  • Plans in the individual market, and
  • Certain grandfathered group health plans and other coverage as recognized by Health and Human Services (HHS) in coordination with IRS.
The penalty will be phased in beginning in 2014 and fully implemented in 2016.

Penalty - The penalty for noncompliance is the greater of:

(A) The sum of the monthly penalty amounts for months in the taxable year during which 1 or more such failures occurred, or

(B)  An amount equal to the national average premium for qualified health plans which have a bronze level of coverage, provide coverage for the applicable family size involved, and are offered through Exchanges for plan years beginning in the calendar year with or within which the taxable year ends.

Monthly Penalty Amounts – The monthly penalty amount is an amount equal to 1/12 of the greater of the following amounts:

(A) Flat dollar amount – (See computation of the flat dollar amount below)

(B) Percentage of income - An amount equal to the applicable percentage for the year (see table below) multiplied by the amount the taxpayer's household income for the year exceeds the taxpayer's income tax filing threshold.

Year    2014 2015 2016
Flat Dollar Amounts (Annual)
  Adult $95.00 $325.00 $695.00
  Individual Under 18 $47.50 $162.50 $347.50
Percentage of Income Rates: 1.0% 2.0% 2.5%
After 2016 the values will be inflation adjusted


Flat Dollar Amount – The flat dollar amount is the lesser of:

1. The sum of the applicable dollar amounts (see table below) for all individuals who were not covered for the month or

2. 300% of the per adult penalty (maximum $2,085 in 2016).

Example - Unmarried taxpayer without minimum essential coverage - In 2016, Gil is an unmarried individual with no dependents who doesn't have minimum essential coverage for any month in 2016. Gil's household income is $120,000 and his applicable filing threshold is $12,000*. The annual national average bronze plan premium for Gil is $5,000*. For each month in 2016, from the table, Gil's applicable dollar amount is $695.
  • Gil's flat dollar amount is $695 (the lesser of $695 and $2,085 ($695 x 3)).
  • Gil's percentage of excess household income amount is $2,700 (($120,000-$12,000) x 0.025).
  • The monthly penalty is 1/12 of the greater of foregoing amounts.  Therefore, the monthly penalty amount is $225 ($2,700/12)).  Of course the sum of the monthly penalty amounts is $2,700, unless Gil qualifies for the short coverage gap grace period (explained later in this chapter).
  • The penalty is the lesser of the sum of the monthly penalty amounts ($2,700) and the cost of the bronze coverage ($5,000).  Thus the penalty is $2,700.
*These amounts are estimates for purposes of the example.

Why Are Monthly Amounts & Annual Amounts Determined?

As you went through the example above you probably asked yourself, why do I compute an annual amount and then divide it by 12 and then turn around and multiply it by 12 again to get the annual amount?  There is a logical reason.  Even though the percentage of income calculation is based upon annual household income less the filing threshold amount times a fixed percentage, the flat dollar amount could change during the year due to marriage, death, children, etc.  Thus if the dollar amount turns out to be the greater amount, the sum of those dollar amounts will be used and each month may be different.


If an applicable individual has not attained the age of 18 as of the beginning of a month, the “applicable dollar amount” for the month will be equal to one-half of the amount shown in the table.

Definition of a Month for Coverage - For any calendar month, an individual is treated as having minimum essential coverage if the individual is enrolled in and entitled to receive benefits under a qualifying program or plan for at least one day. (Reg. § 1.5000A-1(b))

Liability for Dependent Coverage – Under Code Sec 5000A, nonexempt individuals are subject to the penalty for any dependent that may be claimed on their tax return not just those that they actually claim. The penalty applies regardless if they claim them (Reg Sec 1.5000A-1(c)).  

This will prove to be a problem in divorce situations where one parent has custody of a child and claims the child as a dependent, but the noncustodial parent is required by the divorce decree to pay for medical insurance, and has not done so or has purchased coverage that does not meet the minimum essential coverage requirement. The final IRS regulations make no exception for these circumstances and the custodial parent is liable for the penalty. However, Health and Human Services (HHS) has addressed this situation in guidance that permits Exchanges to grant a hardship exemption under 45 CFR 155.605(g)(1) to the custodial parent for a child in this situation if the child is ineligible for coverage under Medicaid or the Children's Health Insurance Program (CHIP). See HHS Center for Consumer Information & Insurance Oversight, Guidance on Hardship Exemption Criteria and Special Enrollment Periods (June 26, 2013). (T.D. 9632, Summary of Comments and Explanation of Revisions)

If an individual may be claimed as a dependent by more than one taxpayer in the same year, the taxpayer who properly claims the individual as a dependent is liable for the shared responsibility payment attributable to the individual. If more than one taxpayer may claim an individual as a dependent in the same year but no one claims the individual as a dependent, the taxpayer with priority under the dependency tie-breaker rules to claim the individual as a dependent is liable for the individual's shared responsibility payment. (Reg 1.5000A-1(c)(2))

Family Size - For computing a taxpayer's shared responsibility payment with respect to any nonexempt individual included in the taxpayer's shared responsibility family, the final regs clarify that the applicable family size involved for purposes of identifying the appropriate bronze level plan includes only the nonexempt members of the taxpayer's shared responsibility family who do not have minimum essential coverage. (Reg. § 1.5000A-4)

Household Income - Household income is the sum of the modified adjusted gross incomes (MAGIs) of the taxpayer and all individuals accounted for in the family size required to file a tax return for that year. Modified AGI means AGI increased by all tax-exempt interest and foreign earned income.

Penalty Enforcement - For a joint return, the individual and spouse are jointly liable for any penalty payment.  The penalty is not subject to the enforcement provisions of subtitle F of the Code and the use of liens and seizures otherwise authorized for collection of taxes does not apply to the collection of this penalty. Noncompliance with the personal responsibility requirement to have health coverage is not subject to criminal or civil penalties under the Code and interest does not accrue for failure to pay such assessments in a timely manner. Therefore, enforcement is generally limited to seizing a refund.

Three-Month Grace Period – No penalty is assessed for individuals who do not maintain health insurance for a period of three months or less during the tax year. If an individual exceeds the three-month maximum during the taxable year, the penalty for the full duration of the gap during the year is applied. If there are multiple gaps in coverage during a calendar year, the exemption from penalty applies only to the first such gap in coverage. IRS is to provide rules when a coverage gap includes months in multiple calendar years.

Taxpayers Exempt from the Penalty –The coverage requirement does not apply to:
  • Individuals who cannot afford coverage because their required contribution for employer-sponsored coverage or the lowest cost “bronze plan” in the local Insurance Exchange exceeds 8% of household income for the year. After 2014, the 8% exemption is increased by the amount by which premium growth exceeds income growth. If self-only coverage is affordable to an employee, but family coverage is unaffordable, the employee is subject to the penalty if he does not maintain minimum essential coverage. However, any individual eligible for employer coverage due to a relationship with an employee (e.g. spouse or child of employee) is exempt from the penalty if that individual does not maintain minimum essential coverage because family coverage is not affordable (i.e., exceeds 8% of household income).

  • Taxpayers with income below the income tax filing threshold (which for 2013 generally is $10,000 for a single person or a married person filing separately and is $20,000 for married filing jointly).

  • Those exempted for religious reasons (who must be members of a recognized religious sect exempting them from self-employment taxes).

  • Individuals residing outside of the U.S. (who are deemed to maintain minimum essential coverage).

  • Individuals who are incarcerated or are not legally present in the U.S.

  • All members of Indian tribes.

Premium Tax Credit

To help low income individuals and families afford health insurance the Premium Tax Credit was devised and provides a form of subsidy to help them pay the cost of health insurance.  In order to qualify for the credit the health insurance must be obtained through a state insurance Marketplace or the federal insurance Marketplace where a state does not have one. 

Generally, eligible individuals and families are those with household income at least 100%*, but not more than 400% of the federal poverty level and who are not offered affordable health insurance under an employer plan, Medicaid or other acceptable coverage.  Based upon the 2016 poverty levels, the credit would phase-out at $46,680 $47,520 for individuals and $97,200 for a family of four.  
  • The 100% is the transition point between where Medicaid qualification ends and marketplace qualification begins. Some states have expanded Medicaid, which provides coverage up to 133% (the amount is inflation adjusted annually and is 138% in 2015).  In those states the 100% is replaced with the expanded Medicaid percentage.   
Eligible individuals and families may enroll in a plan offered through a Marketplace by providing the individual’s or family’s household income to the Marketplace. Based on the information provided to the Marketplace, the family’s poverty level will be determined. Then the Marketplace will determine the amount of premium tax credit to provide in advance to offset the cost of the insurance.

CAUTION:  The credit is based upon income and family size.  Providing incorrect information to the Marketplace can result in too much premium tax credit being applied in advance,  leaving a taxpayer with an unpleasant surprise when they file their tax return and have to pay back the excess.  If during the year there are changes in income and family makeup, immediately reporting those changes to the Marketplace will help to minimize problems.  Failure to notify, as often happens, could cause too large or too little of an advance credit being applied, with the result being the taxpayer will have to repay a portion of credit or get a refund of the excess when they file their tax return. Either way, the credit for the year must be reconciled on the tax return for the year.  

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