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American Benefits Council/AHIP Letter Regarding Code Section 162(m)(6) Issues: The Deduction Limit Applicable to Deferred Compensation (PDF)
American Benefits Council; America's Health Insurance Plans [AHIP] [Opinion] Mar. 24, 2011 7 pages. "In any event, given the variety and complexity of compensation arrangements (including in particular defined benefit SERPS), and regardless of the number of safe harbors provided, guidance should provide that any reasonable method for allocating earnings would be permitted." |
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