In February of 2015, IRS issued Notice 2015-16 which was intended to discuss a number of potential approaches to the implementation of pieces of the tax. At the time, IRS requested comment on a number of issues including the definition of applicable coverage, how to figure the cost of that coverage, and the caps used to calculate the tax.

In July of 2015, IRS issued Notice 2015-52 (downloads as a pdf) to address even more concerns, including who may be liable for the tax, employer aggregation, allocation of tax and payment of the tax. Here are some of the highlights with a little bit of commentary: