Instructions For Form Tir 07-16: Personal Income Tax Treatment Of Employer-Provided Health Insurance Coverage For An Employee'S Child Page 4

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for Massachusetts purposes where the health care coverage is required by state law. For an affected
employee, the Massachusetts gross income for the year, as reflected in his or her W-2, will be lower
than federal gross income.
B. When does an employee’s child meet the definition of dependent for purposes of employer-
provided health insurance coverage so that the entire value of the coverage is excluded from
gross income?
Under federal tax law, employer contributions for health insurance are excluded from an employee’s
gross income. However, the exclusion is limited to contributions made for coverage of the employee,
the employee’s spouse, and the employee’s dependents.
In general, for a child to be considered a dependent under the Internal Revenue Code, the child must
meet the requirements of a “qualifying child” or a “qualifying relative” as described below. Pursuant to
IRS Notice 2004-79, the definition of “dependent” for purposes of the exclusion from gross income for
employer-provided health insurance benefits is broader than the definition for purposes of claiming the
dependency exemption for the child on the parent’s federal income tax return. So achild may qualify
as a dependent for purposes of the exclusion from gross income for employer-provided health
insurance benefits whether or not the parent actually claims the dependency exemption for the child
on the parent’s federal income tax return.
Divorced Parents. For purposes of the exclusion from gross income for employer-provided health
insurance, any child of divorced parents who meets the expanded definition of dependent in
connection with one parent is treated as a dependent of both parents.
Qualifying Child (Age Requirement):
1.
Relationship: The child must be the taxpayer’s son, daughter, stepchild, sibling or stepsibling. A
descendant of any of the above also qualifies (e.g., taxpayer’s grandchild). A legally adopted child
or a child lawfully placed with the taxpayer for adoption is treated as a taxpayer’s child. A foster
child legally placed with the taxpayer is also treated as the taxpayer’s child.
2.
Residency: The child must have the same principal place of abode as the taxpayer for more than
half of the taxable year. Temporary absences because of special circumstances, including illness,
education, business, vacation or military service, do not prevent the child from qualifying.
3.
Age: In general, the child must be under age 19 (or under age 24 if a full-time student) as of the
end of the calendar year. In the case of an individual who is permanently and totally disabled, the
age limits are waived.
4.
Support: The child must not have provided more than half of his or her support for the year.
If a taxpayer’s child does not meet the requirements of a dependent as a “qualifying child,” the
child may still meet the requirements of a dependent as a “qualifying relative.”
Qualifying Relative (No Age Requirement):
1.
Support: The child must have received over half of his or her support from the taxpayer for the
calendar year. In contrast to the rules for a qualifying child (see above), there is no residency
requirement for a taxpayer’s child to meet the definition of a qualifying
relative.[5]
2.
Income limits: Under IRS Notice 2004-79, for purposes of determining whether there is an
exclusion from gross income for employer-provided health care benefits, there is no limit on the
child’s gross income. (By contrast, for purposes of determining whether a child is a “qualifying
relative” for the dependency exemption, the child’s gross income must not exceed the exemption
amount of $3,400 for 2007.)
C. When does employer-provided health insurance coverage for an employee’s child result in
imputed income to the employee?
In the context of employer-provided health insurance benefits, the following examples illustrate when
imputed income occurs and when it does not.
Example 1. A child, age 25, who earns $10,000 receives over half of her support from her mother
and is included in the mother’s employer-provided health insurance coverage.

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