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Committee: Employee Benefits and Executive Compensation
Letter to the IRS commenting on (Notice 2012-40) whether the use-it-or-lose-it rule as applied to health care flexible spending arrangements (Health FSAs) should be modified (August 2012) ( PDF format )
Subject area: Health Care Flexible Spending Arrangements

Letter to the IRS commenting on longevity annuity contracts (QLAC's) (May 2012) ( PDF format )
Subject area: Qualifying Longevity Anbuity Contracts

Letter to the IRS on the safe harbor for determining the affordability of employer-sponsored health coverage for purposes of the shared employer responsibility provisions of the Patient Protection and Affordable Car Act (December 2011) ( PDF format )
Subject area: Health Plans and Health Insurance Coverage

Letter to the Department of Labor commenting on the definition of the term "fiduciary" under ERISA (January 2011) ( PDF format )
Subject area: ERISA

Letter to the IRS concerning group health plans and health insurance coverage relating to status as a grandfathered plan under the Patient Protection and Affordable Care Act (August 2010) ( PDF format )
Subject area: Health Plans and Health Insurance Coverage

Letter to the IRS commenting on Notice 2010-6 (Correcting Documentary Failures Pursuant to Section 409A) (May 2010) ( PDF format )
Subject area: Compensation Plans

Employer Stock Litigation: The Tension Between ERISA Fiduciary Obligations and Employee Stock Ownership ( PDF format )
Subject area: Corporate retirement programs