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American Benefits Council Comment Letter to IRS Requesting Guidance on HATFA Funding Stabilization Provision (PDF)
American Benefits Council Link to more items from this source
[Opinion]
Aug. 18, 2014
9 pages. "[S]ubject to a contrary election by the plan sponsor, the Act modifies the segment rates for a year prior to the year of enactment.... The core point here is that Congress intended for employers to be able to fully use the modified segment rates for 2013, despite the fact that we are now well into 2014. So Congressional intent is clear; any deadlines or rules that would prevent an employer from fully using the modified segment rates for 2013 should not apply."

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