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Premium Tax Credit Proposed Regulations (REG-101576-26): No Cap on Excess APTC Repayment from 2026 and Tighter Immigration-Status Eligibility from 2027—What Marketplace Enrollees and Mixed-Status Families Should Do Now | YCL CPA
Individual & family tax · Oct 15, 2026

Premium Tax Credit Proposed Regulations (REG-101576-26): No Cap on Excess APTC Repayment from 2026 and Tighter Immigration-Status Eligibility from 2027—What Marketplace Enrollees and Mixed-Status Families Should Do Now | YCL CPA

On October 14, 2026, Treasury and the IRS proposed regulations (REG-101576-26) implementing OBBBA's premium tax credit changes: for tax years beginning after December 31, 2025, excess advance PTC must be repaid in full with no cap, and from 2027 family members who are lawfully present but not "eligible aliens" are excluded from the PTC computation. Update your Marketplace income estimate now, confirm each family member's status category before 2027 coverage, and note that comments are due November 30, 2026.

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