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IRS Defers (But Does Not Eliminate) Cafeteria Plan and FSA Forfeitures (PDF)
Alston & Bird LLP 
May 23, 2005
10 pages. Insightful, detailed analysis of Notice 2005-42. Excerpt: [T]he new rule does NOT fit well with existing law and may result in a host of administrative and compliance headaches.... [T]he rule as written could create additional HIPAA and COBRA compliance obligations for Health FSAs.
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