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Kilpatrick Townsend Comment Letter to IRS on Proposed ACA Regs on Employer Shared Responsibility
Kilpatrick Townsend
[Opinion] Mar. 18, 2013
"[This comment letter is] submitted on behalf of two separate Fortune 500 companies [whose] group health plans ... have in excess of 400,000 employees and covered dependents ... Crediting Hours of Service for a period of time for which no duties are performed should be subject to a maximum crediting period.... [The authors] suggest that the Service apply a maximum time period of six months, after which Hours of Service no longer are required to be credited."
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