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You Make the Call - July 23, 2026

Published:
By: NATP Staff
Tax professional discussing 2026 advance premium tax credit repayment rules with a Marketplace health insurance client

Question: Kenneth and Juli Walker live in Michigan and are enrolled in Marketplace health insurance for 2026. They have a family of four, household income of $140,000 and advance premium tax credits (APTC) of $14,000. Must they repay any of the $14,000 of APTC received during 2026?  

Answer: Yes. Assuming the Walkers’ 2026 household income is $140,000 and their family size is four, they must repay the full $14,000 of APTC. 

The enhanced premium tax credit (PTC) rules that temporarily removed the 400% federal poverty line (FPL) limitation were not extended beyond 2025. As a result, beginning in 2026, taxpayers generally are eligible for the PTC only if household income is at least 100% but not more than 400% of the FPL for their family size. 

For 2026 Marketplace coverage, assume the applicable FPL for a Michigan household of four is $32,150. The Walkers’ household income of $140,000 equals approximately 435.5% of FPL ($140,000 ÷ $32,150 = 435.5%). 

Because their household income exceeds 400% of FPL, the Walkers are not eligible for the PTC for 2026, even though more favorable rules allowed the PTC for 2025. Therefore, their allowable PTC is zero. 

Since they received $14,000 of APTC during the year, the entire $14,000 is excess APTC and must be repaid when they file their 2026 federal income tax return. For tax years after 2025, the repayment caps no longer limit the amount of excess APTC that must be repaid. 

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NATP Staff

The NATP team is dedicated to supporting tax professionals with expert insights, industry updates and resources that help them serve their clients with confidence.

Information included in this article is accurate as of the publication date. This post does not reflect tax law changes or IRS guidance that may have occurred after the publishing date.

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