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Ninth Circuit Agrees That 'Highest Contribution Rate' for Withdrawal Liability Payment Calculations Excludes PPA Surcharges
Bolton 
Mar. 24, 2022 "While [MPRA] explicitly excluded surcharges that accrued after 2014 from such calculations, this case concerned surcharges that accrued before 2015. The Ninth Circuit reasoned that the surcharge was not a 'contribution rate' because the PPA surcharge is calculated and paid after the total amount of contributions has been calculated." [Bd. of Trustees of the Western States Office & Professional Employees Pension Fund v. Welfare & Pension Admin. Serv., Inc., No. 20-35545 (9th Cir. Jan. 31, 2022)] |
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