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One-Time Election of Retiree Health Benefits or Increased Pay is Not Constructive Receipt
Deloitte via BenefitsLink 
[Guidance Overview] May 27, 2009
Excerpt: The Internal Revenue Service ruled that an employee's one-time irrevocable election to waive future retiree medical benefits in favor of increased pay did not cause the employee to be in constructive receipt of income under Internal Revenue Code ? 451. IRS Private Letter Ruling 200914018 (Released 4/3/2009).
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