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1 page. Excerpt: On October 22, Carol Gold, the Director of Employee Plans, issued a directive to EP staff regarding certain schemes which use employees with short periods of service to insure that most, or all, of the benefits paid under a retirement plan go to the employer's highly compensated employees (HCEs). The directive states that these schemes may violate the nondiscrimination rules of Code section 401(a)(4)[.]
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