ACA Subsidy · IRC §36B · Rev. Proc. 2025-25 · Form 8962 · TY 2026

Premium Tax Credit Guide 2026

What changed January 1, 2026, when the IRA enhanced subsidies expired. The 400 percent FPL cliff, the Rev. Proc. 2025-25 applicable percentage table, household MAGI, the SLCSP benchmark, Form 8962 reconciliation, and the practitioner playbook for cliff avoidance.

Written by Munib Ur Rehman Reviewed by Nausheen Shahid (LMN Tax Inc.) Updated May 2026 Sources: IRC §36B, IRS Rev. Proc. 2025-25, IRS Pub 974, IRS Form 8962

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Short Answer

The premium tax credit is a refundable federal credit under IRC §36B that offsets ACA Marketplace coverage cost. The 2026 PTC equals the second-lowest-cost silver plan benchmark in your area minus your required contribution (household MAGI × the applicable percentage from Rev. Proc. 2025-25), capped at the actual plan premium. Eligibility runs from 100 to 400 percent of the federal poverty level - the cliff returned January 1, 2026 after the IRA enhanced subsidies expired. For 48-state households the cliff sits at 62,600 dollars (single) or 128,600 dollars (family of four). The applicable percentage runs from 2.10 percent below 133 percent FPL to 9.96 percent flat from 300 to 400 percent FPL. PTC is reconciled on Form 8962 against advance PTC paid during the year.

Key Takeaways

What Changed for the Premium Tax Credit January 1, 2026

The American Rescue Plan Act (ARPA, P.L. 117-2, enacted March 2021) and the Inflation Reduction Act (IRA, P.L. 117-169, enacted August 2022) enhanced the premium tax credit in three ways through plan year 2025: lowered every applicable percentage in the IRC §36B(b)(3)(A)(i) table (top band fell from 9.5 percent to 8.5 percent), eliminated the 400 percent FPL eligibility cliff, and zeroed out the floor band so that households below 150 percent FPL paid nothing for benchmark coverage. These provisions sunset December 31, 2025.

For 2026 plan-year coverage, §36B reverts to its original ACA structure as inflation-adjusted by Rev. Proc. 2025-25. Three things happen simultaneously on January 1, 2026:

  1. The 400 percent FPL cliff returns. Households above 400 percent FPL receive zero PTC. Earning even one dollar above the cliff eliminates the entire subsidy.
  2. The applicable percentage table is higher. The 2026 top band (300-400 percent FPL) is 9.96 percent, up from 8.5 percent in 2025. Every band above 150 percent FPL is higher.
  3. The floor band is reinstated. Households below 133 percent FPL pay 2.10 percent of MAGI for the benchmark plan, where they paid 0 percent under ARPA / IRA.

The combined effect is large. KFF's 2025 analysis projected that average premium payments for subsidized enrollees roughly doubled in 2026 versus 2025 for the same plan, driven both by the underlying premium increases and by the smaller PTC. Households that were comfortable on subsidized Marketplace coverage in 2025 may find 2026 coverage substantially more expensive, with some near the 400 percent FPL line losing PTC entirely.

The 2026 PTC Formula

The PTC for any taxable year is the lesser of (1) the premiums for the qualified health plan(s) the taxpayer is enrolled in through the Marketplace, or (2) the excess of the SLCSP benchmark premium over the taxpayer's required contribution. Stated as a formula:

Annual PTC = min(actual plan premium, max(0, SLCSP − (household MAGI × applicable percentage)))

Each input has a specific source:

The PTC is computed annually on Form 8962. If you received advance PTC during the year, you reconcile against the actual PTC and either receive the difference as a refundable credit or repay the excess.

The 2026 Applicable Percentage Table

Rev. Proc. 2025-25 Table 2 sets the 2026 applicable percentage as a function of household income expressed as a percentage of the federal poverty level. Within each band, the applicable percentage interpolates linearly between the band endpoints.

2026 vs 2025 Applicable Percentage - same household at each FPL band
Household Income (% FPL) 2026 Applicable % 2025 Applicable % (ARPA / IRA) Delta
100% to 133%2.10% (floor)0.00%+2.10pp
133% to 150%3.14% to 4.19%0.00%+3.14 to +4.19pp
150% to 200%4.19% to 6.60%0.00% to 2.00%+4.19 to +4.60pp
200% to 250%6.60% to 8.44%2.00% to 4.00%+4.60 to +4.44pp
250% to 300%8.44% to 9.96%4.00% to 6.00%+4.44 to +3.96pp
300% to 400%9.96% (flat)6.00% to 8.50%+3.96 to +1.46pp
Above 400%N/A (cliff)8.50% (no cliff)Lose entire subsidy

The 9.96 percent figure is also the 2026 affordability percentage for employer-sponsored coverage under §4980H(b) safe harbors. Both numbers move together by statutory design, indexed annually under §36B(b)(3)(A)(ii) to track health-cost growth.

The 2026 Cliff Numbers (48 States + DC)

The cliff is computed on the 2025 HHS poverty guidelines because §36B(d)(3)(B) requires the calculation to use the most recently published poverty guidelines as of the first day of the regular enrollment period for plan-year coverage. Open enrollment for 2026 plan-year coverage opened November 1, 2025; the most recently published guidelines on that date were the 2025 HHS guidelines.

2026 PTC FPL Reference (48 states + DC)
Household Size 100% FPL 250% FPL 400% FPL Cliff
1$15,650$39,125$62,600
2$21,150$52,875$84,600
3$26,650$66,625$106,600
4$32,150$80,375$128,600
5$37,650$94,125$150,600
6$43,150$107,875$172,600

Alaska and Hawaii use higher HHS tables: 2025 Alaska 100 percent FPL is 19,550 (single) + 6,870 per additional person; Hawaii is 17,990 + 6,320. The 400 percent multiplier applies the same way.

How Household MAGI Is Computed

MAGI for the premium tax credit under §36B(d)(2)(B) is a narrow definition that differs from MAGI used for IRA contributions, Roth eligibility, and other purposes. Start with AGI from Form 1040 line 11 and add three items:

  1. Tax-exempt interest (Form 1040 line 2a). Municipal bond interest, qualified savings bond interest, and similar.
  2. Nontaxable Social Security benefits (Form 1040 line 6a minus line 6b). The portion of SS benefits not included in taxable income because of the §86 inclusion limits.
  3. Foreign earned income excluded under §911 (Form 2555).

Household MAGI then equals the taxpayer's MAGI plus the spouse's MAGI on a joint return, plus the MAGI of any dependent who is required to file a return. Dependents who file solely to claim a refund of withheld income tax do not have to be aggregated. The household composition is locked at the time of Marketplace enrollment but can be updated throughout the year for life events (marriage, divorce, birth, adoption, dependent change).

Common items that surprise taxpayers because they do not show up in regular take-home pay but do count for PTC MAGI: capital gains (taxable interest from a CD that matured, a rental sale, a stock sale), traditional IRA / 401(k) distributions, Roth IRA conversions, taxable Social Security, and Schedule C net profit. Items that are excluded from MAGI because they are excluded from AGI: HSA contributions (above-the-line deduction), traditional IRA / 401(k) / SEP / Solo 401(k) contributions (above-the-line if eligible), and student-loan-interest deduction.

SLCSP: The Second-Lowest-Cost Silver Plan

The SLCSP is the statutory benchmark plan under §36B(b)(2)(A). It is defined as the second-cheapest silver-tier plan available to your tax family in your rating area on each enrollment day. The PTC is computed off the SLCSP - the actual plan you choose to enroll in does not affect the PTC amount.

How to Look Up Your SLCSP

Three methods, in priority order:

Why Bronze + Big PTC Often Wins

Because PTC is fixed by SLCSP regardless of the plan you enroll in, low-income households frequently can enroll in a bronze plan with zero monthly out-of-pocket premium. Example: SLCSP for your household is 9,600 dollars annual. PTC is 4,145 dollars annual. If a bronze plan in your area costs 4,200 dollars annual (lower-tier plans are typically cheaper than silver), you pay 55 dollars per year out of pocket - effectively zero monthly premium - in exchange for a higher deductible. The bronze + big PTC combination is the standard low-cost path for healthy households at moderate FPL bands.

Cost-sharing reductions (CSRs) only apply to silver-tier plans for households 100 to 250 percent FPL, so households in that range often prefer silver to capture the lower deductibles and copays.

Form 8962 Reconciliation Mechanics

Form 8962 is the annual reconciliation of advance PTC against actual PTC. It must be filed with Form 1040 if either (1) the household received advance PTC during the year, or (2) the household enrolled in Marketplace coverage and is claiming PTC at year-end without having taken advance.

The form has four parts:

If actual PTC exceeds advance PTC, the difference flows to Form 1040 line 31 as a refundable credit. If APTC exceeds actual PTC, the excess flows to Schedule 2 line 2 as an additional tax. The IRS will reject electronic returns that received APTC without an accompanying Form 8962, and failing to file Form 8962 in a year you received APTC will block future advance PTC and may stall the next year's refund.

The Cliff-Avoidance Playbook

For households between 380 and 410 percent FPL, the 2026 cliff dominates planning. A single dollar of MAGI above the cliff converts the entire annual PTC into a repayable amount, often 5,000 to 15,000 dollars per household. Practitioners should run a December cliff check on every APTC client in this band.

Above-the-Line MAGI Drops Available Through April 15

Each item is an above-the-line deduction that reduces AGI and therefore reduces MAGI for PTC. Listed in order of typical usefulness:

Within-the-Year Moves

Before December 31, taxpayers can also reduce 2026 MAGI through:

The Math of a Cliff Rescue

Every $1,000 of MAGI you move below the cliff can rescue the entire annual PTC. For a household at 405 percent FPL with a 6,000-dollar APTC, a $1,000 traditional IRA contribution that drops MAGI to 399 percent FPL rescues the full $6,000 - a 600 percent return on the contribution before considering the ordinary income tax savings. Few other tax moves have this risk-adjusted return profile. The catch is that every dollar must net to MAGI - a Roth IRA contribution does not work because Roth contributions are not deductible.

State-Based Exchange Subsidies (CA, NJ, NY, MA, VT, WA)

Six states layer state-funded subsidies on top of federal PTC through their state-based exchanges. State subsidies are funded outside the federal budget and continue regardless of the federal cliff. Eligibility levels and subsidy amounts vary by state and by year:

State subsidies are typically delivered as advance premium reductions through the state Marketplace at enrollment. Form 8962 still computes federal PTC only; state subsidies are reconciled separately on the state income tax return where applicable. Verify current eligibility on your state Marketplace's website during open enrollment.

Reporting and Documentation

Three documents drive PTC reporting:

For taxpayers receiving APTC, the IRS auto-flags returns missing Form 8962 and pauses processing. Common practitioner errors: filing without Form 8962 when 1095-A was issued, mismatching family size between Marketplace and tax return, MAGI mistakes (forgetting tax-exempt interest), and using the wrong SLCSP after a mid-year coverage change. The Marketplace allocations on Form 1095-A are authoritative for monthly amounts; if you believe a column is wrong, correct it through the Marketplace before filing.

Practitioner Insight

The single largest 2026 PTC trap is letting a self-employed client float through the year on a low projected income, then absorbing a strong Q4 with no Marketplace update. APTC that was set in November 2025 at projected 320 percent FPL stays at that level all year unless the client logs in to update it. A strong Q4 - new clients, retainer increases, year-end product launches - that pushes final MAGI to 410 percent FPL converts a $5,000 APTC into a $5,000 owed amount on Schedule 2 line 2. The cliff does not negotiate. Practical workflow: at every quarterly tax check-in with self-employed clients, run a four-line calculation - YTD net SE income, annualized projection, household MAGI projection (add interest, capital gains, spouse income), FPL%. If the projection lands above 380 percent FPL, recommend an immediate Marketplace projection update plus a year-end MAGI plan (HSA / IRA / Solo 401(k)). Document the recommendation in the client file. The deferred-income strategies (push December bonus to January, defer Roth conversion) only work if the client has the conversation in November or earlier - deferred-income moves cannot be made retroactively. The practitioner who catches the 2026 cliff trap once for a client wins them for the next ten years.

Real-World Scenario: Couple at 405% FPL Rescues $9,800 With a Late IRA Contribution

James and Diana are a married couple in their early 50s. Diana is a freelance graphic designer (Schedule C); James is a part-time consultant. They project household MAGI of 110,000 dollars for 2026 and enroll in 2026 Marketplace coverage in November 2025 at projected 367 percent FPL (110,000 / 30,000). They take APTC of 815 dollars per month - 9,780 dollars annual - on a silver plan with annual premium 13,200 dollars and SLCSP 14,150 dollars. Out-of-pocket monthly: 285 dollars.

Year-end surprise: Diana lands a new client in October that pays 20,000 dollars by year end. Final 2026 MAGI: 130,000 dollars. Family of two 100% FPL = 21,150. 130,000 / 21,150 = 615 percent FPL - well past the 400 percent cliff at 84,600 dollars.

What Form 8962 looks like without intervention: Final PTC at 615 percent FPL = $0 (cliff). Advance PTC received = $9,780. Excess APTC owed = $9,780. Repayment is uncapped under §36B(f)(2)(B) because final MAGI is at or above 400 percent FPL. Schedule 2 line 2 = $9,780 added to their 2026 federal tax bill on top of normal income tax on the extra income.

The rescue: Their tax preparer, in March 2027, screens for cliff exposure during 2026 return prep. He calculates that to drop MAGI from 130,000 to 84,600 (cliff edge for HH-2) requires a 45,400-dollar reduction. Diana has not yet funded a 2026 SEP-IRA. As a sole proprietor filing Schedule C, Diana can contribute up to ~25 percent of net SE earnings (after the half SE tax deduction) to a SEP-IRA. With 70,000 dollars of net SE income for 2026, a 13,000-dollar SEP-IRA contribution is feasible. James has no workplace plan and can contribute 8,000 dollars to a traditional IRA (50+ catch-up). Total above-the-line MAGI drop: 21,000 dollars. New MAGI: 109,000, which is 515 percent FPL - still above the cliff, but the cliff bite is unchanged because they remain above 400 percent FPL.

The full rescue requires more. The preparer adds a 4,400-dollar HSA contribution (Diana has HDHP coverage), bringing the total drop to 25,400 dollars. New MAGI: 104,600 - still 495 percent FPL, still above the cliff. To rescue the full $9,780, MAGI must drop to 84,600 or below. They are 20,000 dollars short. The remaining options: Diana opens a Solo 401(k) for 2026 (must be set up by December 31, but allows 2026-tax-year employee elective deferral up to $24,500 if it had been set up in time; with a SEP-IRA already partially funded, she switches gears next year). Without time travel, the practical 2026 rescue tops out at about $25,000 of MAGI drop, leaving $20,000 above the cliff and the full $9,780 owed.

The real lesson: Practitioners cannot rescue every cliff exposure in March-April after the fact. Every self-employed client over 380 percent FPL needs a December cliff check, a Solo 401(k) opened by December 31 (a five-minute administrative step), and a Marketplace projection updated at every quarterly check-in. James and Diana's preparer in this scenario does the right thing now and saves them roughly $5,500 against what could have been $9,780. The remaining $4,300 is the cost of not running the December check.

When the Standard PTC Calculation Does Not Apply

  • Mid-year coverage changes. Marketplace coverage that starts or ends mid-year requires month-by-month PTC computation on Form 8962 Part II Column (a). Apply the applicable percentage and benchmark to each month's enrollment status.
  • Dual coverage with employer-sponsored plan. If you had affordable employer-sponsored coverage offered for any month, you are PTC-ineligible for that month. The 2026 affordability threshold is 9.96 percent of household income for employee-only coverage per Rev. Proc. 2025-25.
  • Marriage during the year. Form 8962 Part V provides an alternative calculation for months before marriage that uses pre-marriage household composition. Marriage often improves PTC because each spouse's pre-marriage MAGI gets credited against pre-marriage household FPL.
  • Native American households. Members of federally recognized tribes have monthly enrollment, special PTC and CSR rules, and may be exempt from the individual mandate. Use IHS / IRS Form 8965 guidance, not the standard Form 8962 flow.
  • Below 100% FPL households. Medicaid-eligible in expansion states; in non-expansion states the household may fall in the coverage gap with no PTC and no Medicaid. Cannot compute PTC under standard formula.
  • Self-employed health insurance deduction interaction. §162(l) deduction reduces AGI which reduces MAGI which changes PTC, creating a circular calculation. Pub 974 provides the iterative method; most software handles it.
  • Estimated income changes during open enrollment. Use the Marketplace's tax tool to update projections when income changes; do not wait for year-end. APTC paid is reconciled against actual; bigger gaps mean bigger reconciliation hits.

FAQ: Premium Tax Credit and the 2026 Cliff

Did the ACA premium tax credit really get smaller in 2026?
Yes, materially. The American Rescue Plan Act enhancements (extended by the Inflation Reduction Act through 2025) expired December 31, 2025. Beginning with 2026 plan-year coverage the rules revert to the pre-ARPA structure under IRC section 36B as enacted. Three things changed simultaneously on January 1, 2026: the 400 percent FPL eligibility cliff returned, the applicable percentage table per Rev. Proc. 2025-25 is higher across every band (top band is 9.96 percent for 300-400 percent FPL, vs 8.5 percent under ARPA), and the floor band starts at 2.10 percent below 133 percent FPL where it was zero under ARPA. KFF estimated average premium payments for subsidized enrollees roughly doubled in 2026 versus 2025 for the same plan.
How is household MAGI computed for the premium tax credit?
Modified AGI for PTC under IRC section 36B(d)(2)(B) starts with Adjusted Gross Income (Form 1040 line 11) and adds three items: tax-exempt interest (Form 1040 line 2a), the nontaxable portion of Social Security benefits (Form 1040 line 6a minus line 6b), and any foreign earned income excluded under section 911. Household MAGI is the MAGI of the taxpayer plus the MAGI of the spouse if MFJ, plus the MAGI of any dependent who is required to file a return. Dependents who file only to claim a refund of withheld tax do not contribute. PTC MAGI is narrower than the ACA individual-mandate MAGI used elsewhere - confirm the section 36B definition specifically.
What is the second-lowest-cost silver plan and why does it matter?
The second-lowest-cost silver plan (SLCSP) is the statutory benchmark used to compute the PTC under IRC section 36B(b)(2)(A). It is the second-cheapest silver-tier plan available to your tax family in your rating area on the day you enroll. Your PTC equals the SLCSP minus your required contribution - the actual plan you enroll in does not affect the PTC amount, only the SLCSP does. You can enroll in a bronze plan to capture the entire PTC at zero out-of-pocket monthly premium, or upgrade to gold or platinum and pay the difference. SLCSP is looked up at healthcare.gov/tax-tool by ZIP code and family composition, or read off Form 1095-A Part III column B.
What is the practitioner playbook for the 400 percent FPL cliff?
For 2026 plan-year reconciliation in March-April 2027, run a December cliff check on every APTC client whose projected MAGI is between 380 and 410 percent FPL. If projected final MAGI is above 400 percent FPL, look for above-the-line MAGI drops that the client can still execute by April 15: traditional IRA contribution (up to $7,000 / $8,000 if age 50+), HSA contribution (up to $4,400 / $8,750 if HDHP-covered), self-employed retirement plan contributions (SEP / Solo 401(k) up to October 15 with extension). Each $1,000 of MAGI below the cliff can rescue $5,000 to $12,000 of APTC repayment. Document the rescue in the workpapers. For clients well above the cliff, advise to shop off-Marketplace or check state-based subsidies in CA / NJ / NY / MA / VT / WA.
How does Form 8962 reconciliation work?
Form 8962 reconciles the advance PTC paid to your insurer during the year against the actual PTC you qualified for. Part I computes household income and family size. Part II computes monthly PTC and APTC by month using Form 1095-A column A (premium paid), column B (SLCSP benchmark), and column C (advance PTC). If actual PTC exceeds APTC, the difference is a refundable credit on Form 1040 line 31. If APTC exceeds actual PTC (you under-projected income), the excess is repaid on Schedule 2 line 2. Repayment is capped on a sliding scale for households below 400 percent FPL and uncapped at or above 400 percent FPL. You must file Form 8962 if you received any APTC during the year; failing to file blocks future APTC and can stall the refund.
Why are MFS filers barred from the premium tax credit?
IRC section 36B(c)(1)(C) provides that married taxpayers must file MFJ to claim the PTC. The bar reflects the original ACA design choice that PTC eligibility be based on combined household income, which an MFJ return reports cleanly. The only exception is the abuse / abandonment safe harbor under Treas. Reg. section 1.36B-2T(b)(2): a married filer living apart from a spouse, who is unable to file MFJ because of domestic abuse or spousal abandonment, may file MFS and still claim PTC if they attest to the qualifying circumstances on the return. The safe harbor is narrow and the IRS audits compliance carefully. Outside the safe harbor, MFS households must enroll without APTC and face no PTC at year end.
What if my employer offers health insurance? Can I still get the premium tax credit?
You are PTC-ineligible if your employer offers minimum-essential, affordable, minimum-value coverage. Affordability for 2026 is tested against 9.96 percent of household income per Rev. Proc. 2025-25 (the same percentage as the 300-400 percent FPL applicable percentage, by statutory design). The Treas. Reg. section 1.36B-2(c)(3)(v)(C) reform effective 2023 closed the family glitch: affordability is now tested separately for the employee (using the employee-only premium) and dependents (using the family premium). So a family where employee-only coverage is affordable but family coverage is not affordable can have the spouse and children enroll on the Marketplace with PTC even though the employee cannot. You attest to employer offer status on Marketplace application and reconcile against employer ICHRA / QSEHRA notices on Form 1095-C.
What about state-based exchange subsidies?
Six states layer state-funded subsidies on top of federal PTC. California (Covered California state subsidy program), New Jersey (NJ Health Plan Savings), New York (Essential Plan + state subsidy), Massachusetts (ConnectorCare), Vermont (Vermont Premium Assistance), and Washington (Cascade Care subsidies) extend financial help that may continue above 400 percent FPL even after the federal cliff returned. State subsidy levels and income thresholds vary by program and are funded through state budgets, so verify current eligibility on your state Marketplace's website. The federal Form 8962 still computes federal PTC only; state subsidies are typically delivered as advance premium reductions through the state Marketplace.
How does the self-employed health insurance deduction interact with PTC?
Self-employed taxpayers can deduct unreimbursed health insurance premiums above-the-line under IRC section 162(l) up to net SE income. The deduction reduces AGI which reduces MAGI which may change PTC eligibility and amount. Section 162(l)(7) requires the deduction to be reduced by the PTC: you cannot deduct premiums that the federal government already paid through PTC. The interaction is circular - the deduction depends on PTC which depends on MAGI which depends on the deduction. IRS Pub 974 provides an iterative method to solve the loop, and most tax software handles it automatically. For practitioners, the practical impact is that self-employed clients hovering near the 400 percent FPL cliff often benefit from a higher Solo 401(k) or SEP-IRA contribution rather than relying solely on the section 162(l) deduction, because the retirement contribution is a clean above-the-line MAGI drop without the circular interaction.
Will Congress restore the enhanced subsidies for 2027?
As of May 2026 the enhanced subsidies remain expired and no replacement legislation has been enacted. CRS report R48290 documents the policy debate and several proposed extensions that did not advance. The 2026 reset is in effect for 2026 plan-year coverage and, absent legislative action, will continue for 2027. Open enrollment for 2027 plan-year coverage opens November 1, 2026; the 2026 HHS poverty guidelines (published January 2026) will be the lookup year for 2027 plan-year PTC, and the 2027 applicable percentage table will be issued by the IRS in summer 2026 via a successor to Rev. Proc. 2025-25. Households should plan around the cliff continuing through at least 2027.
Official Sources

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Decision Step: Choosing Your 2026 Marketplace Strategy

Route A - Confidently Below 400% FPL

Run the Premium Tax Credit Calculator with your projected MAGI. Take APTC and pay your monthly net premium. File Form 8962 to reconcile. If income comes in lower, additional PTC flows as a refundable credit. Higher income triggers sliding-scale repayment under 400% FPL.

Route B - 380-410% FPL Danger Zone

Run the cliff check by December 1. Open a Solo 401(k) by December 31 if self-employed. Earmark a traditional IRA / HSA contribution by April 15 if needed. Each dollar of MAGI you lock below the cliff rescues several thousand of APTC. The HSA Calculator + SEP / Solo 401(k) Calculator size the moves.

Route C - Above 400% FPL With No Realistic Way Down

Federal PTC = $0 for 2026. Shop off-Marketplace for unsubsidized coverage (often slightly cheaper than Marketplace silver plans of equivalent metal tier), check state-based subsidies if you live in CA / NJ / NY / MA / VT / WA, and if you are self-employed, deduct the full premium under §162(l) using the Self-Employment Tax Calculator.

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