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ABA Tax Section Comment Letter to IRS on Proposed 4980F Regs: ERISA 204(h) Notices (PDF)
Section of Taxation, American Bar Association 
Nov. 13, 2002
16 pages. Excerpt: Final regulations should define the scope of the terms 'early retirement benefits' and 'retirement-type subsidies,' both for purposes of section 204(h) of ERISA and section 411(d)(6) of the Code.... Final regulations should affirmatively state that section 204(h) notice requirements do not apply to plan amendments adding minimum benefits, even if such amendments may result in 'wear-aways' for some participants ...
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