I am not an expert in these laws, and I have had a difficult time getting clear guidelines to these rules. But, it is not clear to me why the questioner is not considered to have minimum essential coverage in the above situation.
Irs publication 974 states:
The Department of Health and Human Services has designated the following health benefit plans or arrangements as minimum essential coverage.
1.
Employer coverage provided to business owners who are not employees.
2.
Coverage under a group health plan provided through insurance regulated by a foreign government if:
a.
A covered individual is physically absent from the United States for at least 1 day during the month, or
b.
A covered individual is physically present in the United States for a full month and the coverage provides health benefits within the United States while the individual is on expatriate status.
Doesn't #2a potentially apply for September-December in the above situation?
