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Defined Benefit Combo Cash Balance Compliance Consultant Loren D. Stark Company (LDSCO)
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IRS Discusses Areas Unaddressed So Far in Shared Responsibility Payment Guidance and Safe Harbors
Wolters Kluwer Law & Business Oct. 2, 2012 "The first safe harbor in Notice 2012-58 expands to 12 months the look-back measurement period for employers to determine whether their ongoing employee is a full-time employee under Code Sec. 4980H.... 'What guidance has done is try to give employers a way of fairly establishing what employees are full-time [for purposes of the requirement to offer health care coverage],' said [Rachel Levy, attorney-advisor in the Treasury Office of Benefits Tax Counsel].... She added that the guidance had not, however, addressed employees who transfer between different jobs for the same employer. Nor had the IRS or Treasury finished their analysis of requested comments on high-turn- over employees, meaning employees hired to a full-time position where the employer knows a large percentage of its hires will leave within three months. Additionally, the IRS and Treasury are open to comments concerning employees hired to work for more than 30 hours a week, but for a period just over three months." |
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