12 December 2018

Michigan HICA Tax Officially Repealed!

As explained in our previous client alert (which can be found here), Michigan officially repealed the Health Insurance Claims Assessment (HICA) tax on June 11, 2018.  However, that repeal was conditioned on the approval of its replacement—the Insurance Provider Assessment (IPA)—by the Centers for Medicare & Medicaid Services (CMS). On December 11, 2018, CMS notified […]


10 December 2018

Naughty or Nice? OFCCP Issues Three New Directives

Welcome to another Two Minute Update.  The OFCCP recently issued three new policy directives. The first one is aimed at clarifying the Agency’s compliance review procedures.  This rescinds an Obama era directive that replaced shortened desk audits with much more “deep dive” full audits.  Instead, OFCCP’s Compliance Manual will be followed moving forward.  The stated goal […]


16 November 2018

A (Retirement Plan) Match Not Made In Heaven!

The recent IRS ruling allowing employers to make retirement plan contributions for participants who are repaying student loans even though they are not contributing to the employer’s 401(k) plan has received a lot of attention.  Unfortunately, most of the attention has been from employers who want to continue to offer matching contributions and to make […]


08 November 2018

Proposal 1 Passes in Michigan: What Employers Need to Know

On Tuesday, Michigan voters passed Proposal 1, or what will now be known as the Michigan Regulation and Taxation of Marihuana Act.  Although Michigan voters passed the proposal to legalize marijuana for adult recreational use, employers can still “just say no” to hiring or retaining employees who violate workplace drug policies. Technically, what does Proposal […]


02 November 2018

IRS Announces 2019 Annual Limits on Various Employee Benefits

The IRS recently released inflation-adjusted limitations that apply to various employee benefits in 2019. Social Security Taxable Wage Base for 2019 The Social Security Administration recently announced that the maximum amount of earnings subject to Social Security tax is $132,900, which is an increase of $4,500 from 2018. Retirement Plan Dollar Limitations for 2019 The […]


10 September 2018

Two Minute Update: Pay It Again, Uncle Sam – OFCCP Compensation Review Update

In past years, OFCCP has settled pay discrimination cases for several million dollars in back pay.  Recently, it rolled out another tool to uncover evidence of gender and race-related pay disparities.  For the third time in 10 years, OFCCP overhauled its standards about how it will analyze a contractor’s pay decisions.  The new comp directive doesn’t really […]


27 August 2018

Don’t Forget to Update Your DOL Apprenticeship Program

Have a U.S. Department of Labor (DOL)-approved apprenticeship program?  Have you updated it recently?  If not, now is the time. On December 19, 2016, the Department of Labor published a final rule updating the guidelines that dictate how employers ensure equal employment opportunity in apprenticeship programs.  The final rules updated regulations in effect since 1978 […]


24 August 2018

Two Minute Update: Don’t Forget to File Your Vets-4212

Between enjoying the last days of summer and back to school, it can be easy to forget about Veterans Reporting Obligations. But, the time to file your VETS-4212 report is here. Covered federal contractors have an obligation for recordkeeping and reporting under the Vietnam Era Veterans Readjustment Assistance Act or VEVRRA. VEVRAA requires covered contractors […]


22 August 2018

Political Activity Limitations for 501(c)(3) Organizations: Where Are We Now?

***This article appeared in the Summer 2018 issue of the Michigan Business Law Journal.*** Changes to political activity limitations for 501(c)(3) organization has been the subject of much debate, particularly over the last two years. The Johnson Amendment and its favorability to charitable organizations have been hotly contested. The Johnson Amend­ment was proposed by Lyndon Johnson […]