Retirement Plan Relationship Manager ERISA Services, Inc.
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Regional Sales Director (West) July Business Services
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Retirement Solutions Specialists
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July Business Services
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Defined Contribution Account Manager Nova 401(k) Associates
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Defined Contributions Compliance Consultant Loren D. Stark Company (LDSCO)
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Senior Specialist 401k Recordkeeping T Bank N.A.
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Fringe Benefit Group
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TPA Retirement Plan Consultant EPIC RPS (TPA/DPS)
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Secondment, Deferred Compensation, and Subpart F Income: A Potential Trap
Miller & Chevalier [Guidance Overview] July 25, 2010
Excerpt: This article points out that while a secondment agreement, that is properly worded and implemented, may act as an effective shield against Code section 457A, it may also inflict a detrimental blow to the US company's subpart F income. Accordingly, any US company that seconds its employees to related foreign-based entities should re-evaluate that arrangement to assure that it is obtaining the desired tax outcome.
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