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Highlights of American Benefits Council's Discussion with IRS on Relative Value Regulations (PDF)
American Benefits Council 
Apr. 14, 2004
2 pages. Excerpt: The most significant concerns can be classified as (1) most valuable benefit issue, (2) 411(d)(6) issue, (3) retroactive annuity issue, and (4) the need for appropriate review time to avoid widespread compliance problems. These issues are described in more detail below.
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