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IRS Notice Provides Additional Information on Cadillac Tax
Employers Council on Flexible Compensation [ECFC] 
[Guidance Overview] Aug. 2, 2015
"[Notice 2015-52] raises a number of issues with respect to implementation of the excise tax and asks for public comments no later than October 1, 2015. While the new guidance still leaves many open issues, it seems that they have heard our requests related to: [1] the exclusion of carryover amounts from the Cadillac plan tax determination in subsequent years; and [2] the timing of account based plan accruals."
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