Defined Benefit Combo Cash Balance Compliance Consultant Loren D. Stark Company (LDSCO)
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Bates & Company, Inc.
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Loan & Distribution Specialist AimPoint Pension
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Regional Vice President of Sales The Retirement Plan Company
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Compass
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AimPoint Pension
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A Prepper's Guide to ACA Employer Mandate Penalty Assessment
LeFevre Law PC [Guidance Overview] Nov. 14, 2017
"[D]espite the fact that the 2015 Form 1095 instructions and other IRS guidance clearly instructed employers to leave line 16 blank in some circumstances, if the employer did so and the employee got subsidized coverage on one of the exchanges, the employer will very likely receive a penalty assessment notice.... IRS systems have been coded such that if the employer left Form 1094, Part III, column (a) (Minimum Essential Coverage Offer Indicator) blank ... it is presumed to be 'No.' ... Penalty assessments will be purely computer-driven ... Even if transition relief applies, and even if there's a perfectly acceptable reason for line 16 of Form 1095 to be blank, IRS is going to make the employer mount a defense."
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