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Overview of the Backloading Issue: Effect on Both Hybrid and Traditional Plans (PDF)
American Benefits Council 
May 25, 2007
4 pages. Excerpt: [The PPA] did not require 'choice' or 'greater of,' but certainly did not intend to prohibit such pro-participant transition approaches. Unfortunately, the IRS has decided that the generally most generous transition approach - - greater of - - violates the 'backloading rules.' The IRS' interpretation ... is inconsistent with the clear intent of the backloading rules. To explain the IRS' position, it is first necessary to discuss the backloading rules.
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