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ERIC's January 3, 2006, Comments on Proposed Regulations under Code Section 409A (PDF)
The ERISA Industry Committee [ERIC] 
[Opinion] Jan. 6, 2006
43 pages. Excerpt: [T]he proposed regulations do not resolve all of ERIC's concerns, and they raise new concerns as well. In this submission, ERIC recommends specific changes in the proposed regulations to resolve ERIC's concerns. ERIC looks forward to working with the Treasury and the Service on these recommendations.
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