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A Word from the IRS on Involuntary Terminations of Employment for Purposes of the ARPA COBRA Premium Subsidy
ProskauerLink to more items from this source
[Guidance Overview]
June 10, 2021

"Even if a termination is labeled as 'voluntary' or is designated as a resignation, it won't necessarily be voluntary for ARP purposes. [Notice 2021-31] explains that such a termination will be involuntary if the circumstances indicate that the employee was willing and able to work and, absent the employee's termination, the employer would have terminated the employee and the employee had knowledge of that."

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