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Company acquires sub of seller via an asset purchase transaction and decides to employ certain of the sub's employees following close of the transaction. Buyer is an ALE. There will be a lag time until Buyer gets plans in place for the acquired employees (it's putting separate plan in place for the acquired employees). Buyer is considering paying for acquired employees' COBRA under Seller's plan on a tax-free basis. Any thoughts as to whether this will work, or what issues it may raise? What about the ACA concerns? Thanks in advance.