In June 2013, the U.S. Supreme Court struck down Section 3 of the Defense of Marriage Act (DOMA) as unconstitutional. This opened the door for federal recognition of same-sex marriages in states that recognize such unions.

The Obama administration has pledged a thorough and expedited review of federal laws, including federal benefit laws. We expect the agencies to release guidance soon with regard to various health and welfare compliance requirements associated with the tax guidance, potentially including, but not limited to, COBRA qualified beneficiary determinations, Form W-2 reporting changes, plan document, SPD and cafeteria plan document amendments, open enrollment and new hire packet language changes, etc.

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