IRS Notice 2011-2, 2011-2 I.R.B. 1 (Dec. 22, 2010)

(guidelines issued on the application of I.R.C. Sec. 162(m) (which was added by the Health Care Act to limit to $500,000 of earnings per employee the deduction for remuneration for services provided by persons to some health insurance providers and utilizes aggregation rules across consolidated groups; under a deminimis rule, employer not treated as covered health insurance provider for tax years beginning in 2010 and through 2012 if premiums employer receives are less than 2 percent of employer's gross revenues for that tax year; starting in 2013, employer excepted from provider definition if health coverage insurance received from providing minimum essential coverage are less than 2 percent of employer's gross revenues for the year; definition of "applicable individual" under Sec. 162(m)(6)(F) excludes some independent contractors; as for who is a "covered health insurance provider", premiums received under indemnity reinsurance contract are not "premiums" from providing health insurance coverage).