National Coordinating Committee for Multiemployer Plans Comment Letter to IRS on Proposed Section 415 Regulations (PDF)

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National Coordinating Committee for Multiemployer Plans Comment Letter to IRS on Proposed Section 415 Regulations (PDF)
National Coordinating Committee for Multiemployer Plans [NCCMP]

Aug. 4, 2005

4 pages. Excerpt: These comments focus on three features of the proposal of special concern to multiemployer plans: the special rules for plans maintained by more than one employer, the exclusion from the definition ofcompensation of payment for services after the end of direct employment, and the rules on multiple annuity starting dates.

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