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March 22, 2005, Comment Letter on IRS Position on Crediting Contributions for Multiemployer Pensions (PDF)
American Academy of Actuaries
[Opinion] Apr. 1, 2005 2 pages. Excerpt: We are concerned by any limitation on contribution borrowing. For example, if contributions made on hours (or some other basis) in a plan year aren't enough to meet the minimum funding requirement, employers would have an obligation to fund the deficiency, barring any available action the trustees can take to avoid the deficiency. MORE >> |
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