"[E]mployers should: [1] Begin to establish internal procedures for tracking covered employees, and consider strategies to address covered employees in future acquisitions. [2] Ensure that they can identify the extent to which these employees' benefits are grandfathered under the Proposed Regulations.... [3] Determine whether any of their plans require payments to be delayed until the first year in which the employer's deduction for the payment would not be subject to the Code Section 162(m) limit."  MORE >>