American Rescue Plan Act of 2021 Tax Provisions

Costing $1.9 trillion, with over $580 billion attributable to its tax provisions, the American Rescue Plan Act of 2021 (ARPA) is a sweeping piece of legislation attempting to jump-start the economy and relieve the economic suffering of individuals and businesses caused, directly and indirectly, by the coronavirus pandemic. 

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  • ARPA now applies the I.R.C. Sec. 162(m) $1 million limit to the top-five highest-paid employees, in addition to the CEO and CFO (rather than the top three).
  • ARPA requires employers to fully subsidize COBRA premiums for eligible qualified beneficiaries during a six-month period, allowing employers to offset such costs against employment tax liabilities.
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