the United States Government

“ Imposition of tax There is hereby imposed on any employer (including a self-employed person) or employee organization that contributes to a nonconforming group health plan a tax equal to 25 percent of the employer's or employee organization’s expenses incurred during the calendar year for each group health plan to which the employer or employee organization contributes. ”

“ For purposes of the preceding sentence—
(A) all employers treated as a single employer under subsection (a) or (b) of section 52 shall be treated as a single employer, (B) all employees of the members of an affiliated service group (as defined in section 414 (m) ) shall be treated as employed by a single employer, and (C) leased employees (as defined in section 414 (n) (2) ) shall be treated as employees of the person for whom they perform services to the extent they are so treated under section 414 (n) . ”