Regional Vice President of Sales The Retirement Plan Company
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Compass
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AimPoint Pension
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Bates & Company, Inc.
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Defined Benefit Combo Cash Balance Compliance Consultant Loren D. Stark Company (LDSCO)
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Loan & Distribution Specialist AimPoint Pension
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American Benefits Council Comment Letter to IRS on Shared Responsibility for Employers Regarding Health Coverage (Code Section 4980H) (PDF)
American Benefits Council [Opinion] June 16, 2011 9 pages. "[W]e believe employers should [be permitted to] retain discretion not only to decline coverage to appropriate categories of employees in the entirety; they should also be able to provide different levels of coverage so long as the coverage meets the standards set forth in Code section 4980H.... We urge the IRS to issue guidance excluding all seasonal employees (i.e., employees working less than 6 months per year), contract employees, daily employees, and temporary employees from the definition of full-time employee." |
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