Specifically, in Notice 2011-2 the IRS provides guidance on the application of section 162(m)(6) of the Internal Revenue Code (Code). Section 162(m)(6) limits the allowable deduction for remuneration for services provided by individuals to certain health insurance providers. Section 162(m)(6) was added to the Code by section 9014 of the Patient Protection and Affordable Care Act (PPACA).
The IRS notes that Section III of the notice “provides guidance on certain issues the Treasury Department and the IRS have determined require immediate guidance,” while Section V “requests comments as to the application of the provisions of this notice as well as all other aspects of the application of section 162(m)(6)”.
The Treasury Department and the IRS anticipate that the guidance provided in this notice will be incorporated into future regulations issued under section 162(m)(6).
Notice 2011-2 is online at http://www.irs.gov/pub/irs-drop/n-11-02.pdf