"We strongly believe that the impact of this tax will have broader implications than first anticipated by the Joint Tax Committee (JTC) and have been provided information that as many as 25 percent of employers' plans may be subject to the tax.... [T]he regulatory structure must acknowledge three variables that restrict employers' ability to avoid the tax. First, there are certain mandatory benefit offerings in the law that cannot be avoided. Second, there are geographic and age variations in various employer plans that make avoidance more difficult. Third, employers use and value the flexibility allowed under ERISA to design, offer and administer unique plans to their employee population."  MORE >>