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Showing content with the highest reputation on 12/10/2016 in all forums

  1. I am going to respectfully disagree with ETA to a certain extent. As practitioners, we generally speak of the deadline for the SH notice as 30 days before the plan year, or December 1 , 2016 in this case. However, the law simply requires that the notice is distributed within a reasonable period before any year. A notice distributed 30-90 days prior to the beginning of the plan year is deemed to meet the reasonable time period requirement. That does not mean that a notice does not meet the reasonable time period requirement because it is less than 30 days. You would need to satisfy a facts and circumstances test to show that your notice period was reasonable. I am not saying that it is reasonable in the OPs situation, but if the circumstances were right, it is possible that it can be.
    2 points
  2. I knew this day would eventually come "If everyone is thinking alike, then someone isn't thinking." -- W. Edwards Deming
    1 point
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