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The IRS Tells Us That Employer Payment Plans (Really, Really, Really) Don't Work
Mintz Levin Link to more items from this source
[Guidance Overview]
June 2, 2014

"[T]hese penalties are self-reported ... and they apply to large and small employers alike. Thus, employers to whom employer payment plans have been sold as fitting this or that exception to Notice 2013-54 are already subject to penalties. Regrettably, it's a safe bet that these sorts of violations will occur predominantly in small employers with less access to reliable professional advice."

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