Proposed Section 3121(v) regulations: application of employment taxes to nonqualified deferred compensation.
In 1983, when Congress last made broad amendments to the Social Security system, one if its changes was to impose Social Security-related (FICA) taxes upon cash-or-deferred arrangements under section 401(k) of the Code and upon nonqualified deferred compensation by adding section 3121(v) to the Code. Generally, an employee's wages are subject to FICA taxes when they are paid. Employers and employees are equally liable for FICA taxes, which consist of Old-Age, Survivors and Disability Insurance (OASDI) tax (at a rate of 6.2 percent of wages) and Hospital Insurance (Medicare) tax (at a rate of 1.45 percent of wages). Thus, subject to a cap on the amount of wages subject to the OASDI portion of the tax, employers and employees each pay a total tax of 7.65 percent of wages. "Wages" are defined broadly in section 3121(a) to include almost all remuneration provided for services rendered. Amounts deferred under a nonqualified plan, however, are subject to a special rule under section 3121(v). Under this rule, these amounts are subject to FICA taxes on the date on which the services giving rise to the amounts are performed or, if later, the first date on which the employee's rights to the deferred amounts are not subject to a substantial risk of forfeiture. Once an amount is subjected to FICA taxes, it and the income it earns are not taxed again (i.e., when actually paid).
Unfortunately, the statutory language says little more than this, leaving open a number of questions about the precise manner in which section 3121(v) is applied. Specifically, it has been unclear -
*What plans are subject to section 3121(v)
*What constitutes a 'substantial risk of forfeiture'
*How to determine the amount that is required to be subject to FICA tax for any year.
Before publication of the proposed regulations, there was virtually no elaboration on the application of these rules. The only meaningful guidance was the relevant legislative history, very few letter rulings,(1) some language in the instructions to Form W-2 (unrelated to FICA taxation), and a single decision of the U.S. Claims Court.(2) And the guidance provided by these documents was limited indeed: Apart from statements in the legislative history and in the letter ruling to the effect that a "substantial risk of forfeiture" is to be determined in accordance with the principles of section 83, the available guidance addressed only the first of the three issues described above.
For much of the period since the enactment of section 3121(v) in 1983, guidance on its application was largely unnecessary. Because nonqualified deferred compensation is typically paid to higher-paid employees, and because the inclusion of these amounts in the employee's wages subject to FICA tax frequently occurs while the employee is actively employed and typically earning wages in excess of the FICA taxable wage base, the rules of section 3121(v) had essentially no effect. When the cap on the amount of wages taken into account for purposes of the Medicare portion of the FICA taxes was increased to $125,000 in 1991 and then eliminated in 1994, however, clarification of section 3121(v) became critical to enable employers to determine, collect, and remit the taxes. Recognizing this fact, but nevertheless being unprepared to issue comprehensive instruction, the IRS published Internal Revenue Notice 94-96,(3) which permitted taxpayers to adopt any reasonable good-faith interpretation of section 3121(v) until the issuance of regulations. Those regulations have now been issued, in proposed form.
The Proposed Regulations
Plans Subject to Section 3121(v). Generally, any plan that provides for the deferral of compensation from one year to another -even if only for a brief period - is subject to section 312 (v).(4) The proposed regulations do, however, provide several exceptions to this rule.
First, amounts paid in accordance with an employer's ordinary payroll practice after the end of a calendar year and for the final pay period of the year or for a pay period that overlaps the year-end are not amounts deferred under a nonqualified plan. Hence, they are not subject to section 3121(v). (In other words, they are subject to FICA tax when paid.) Second, if amounts are paid within two-and-a-half months after the end of the calendar year in which the employee performed the services for which the payments are being made, the employer may elect to treat these amounts as not being subject to section 3121(v), if all employees and all similar plans are treated alike.(5) Finally, the regulations specifically exclude stock options, stock appreciation rights, stock value rights, awards of restricted property, welfare benefits, benefits provided in connection with certain impending terminations of employment or under a plan established after termination, and excess parachute payments from the scope of section 3121(v). Phantom stock plans, however, are considered deferred compensation plans subject to this section. This rule is consistent with the approach reflected in the instructions to Form W-2.(6)
This purported bright-line test produces some inconsistencies and, therefore, some planning opportunities. In particular, phantom stock arrangements are specifically identified as deferred compensation plans, but stock value rights, which are defined as devices that give an employee the right to the difference between the value of a share of stock and a specified amount greater than zero (apparently to distinguish them from stock appreciation rights), are not. If a stock value right pays the difference between market value and some nominal amount, what is the difference between that arrangement (which is not deferred compensation) and a phantom stock award (which is deferred compensation)?
Similarly, restricted property is specifically excluded from the definition of deferred compensation, but the proposed regulations state that an agreement to pay property in the future may give rise to deferred compensation. What is the difference between, for example, a current grant of restricted stock and an agreement to pay the same number of shares of unrestricted stock in the future coupled with a current grant of dividend equivalents and the ability to direct the vote of that number of shares? Because, depending upon the circumstances, it may be advantageous to treat an amount as deferred compensation rather than current compensation (or vice versa), careful planning may enable an employer to create an arrangement that both meets its desired objectives and produces the desired FICA tax treatment.
Substantial Risk of Forfeiture. Consistent with section 3121(v)'s legislative history and Private Letter Ruling 9051003 the proposed posed regulations provide that whether a substantial risk of forfeiture exists is to be determined in accordance with principles applied under section 83. Thus, an employee's right to deferred amounts is generally subject to a substantial risk of forfeiture for as long as the employee is required to perform additional services to be entitled to payment of the amounts (i.e., until the employee becomes substantially vested' in his benefit under the plan).
Example 1. Company X maintains a nonqualified plan under which an amount equal to ten percent of a participant's compensation is deferred under the plan on the last day of each year. Under the terms of the plan, the participants vest in 20 percent of their interest in the plan on the third anniversary of their participation in the plan and in an additional 20 percent on each succeeding anniversary. A participant in the plan does not have wages as a result of participation in the plan until the third anniversary of the date on which he or she commenced participation. On that date, and on each anniversary of that date, a portion of the participant's interest in the plan ceases to be subject to a substantial risk of forfeiture and, therefore, the participant has wages that are required to be taken into account for FICA purposes as of each of these dates. In addition, the participant has FICA wages each year after becoming 100 percent vested in his or her plan interest. The amount treated as wages in each of these years is generally equal to the value of the participant's vested interest in the plan in each year, reduced by the total amount previously taken into account and by income attributable to that amount. Because the determination of what amount has been taken into account and what amount is interest on that amount can be fairly complicated, a detailed discussion of this issue, including examples, is set forth in the next section of this article.
Determining the Amount Subject to FICA Tax. The rules governing the timing and amount of FICA taxation distinguish between "account balance plans" and "nonaccount balance plans."
* Account Balance Plans. An "account balance plan" is essentially a defined contribution plan - one under which deferred amounts and additional amounts treated as income thereon are credited to a participant's account and the benefit payable from the plan is based solely on the participant's account balance.(7) The section 3121(v) rules for account balance plans are rather straightforward. In a plan that provides for 100-percent vesting in the entire account balance, in the year in which an employee becomes vested in his benefit under such a plan, the amount included in wages subject to FICA tax for the year is the total amount credited to the employee's account at the time he becomes vested (including income on amounts previously deferred, if any). In subsequent years, the FICA wages the employee has for the year generally include only the additional amount deferred for that year. As previously noted, income on amounts previously treated as wages subject to FICA taxes are not subject to these taxes. In a plan that provides for vesting in percentages of the account balance over a period of years, e.g., 20 percent each year beginning on the third anniversary of participation, the same principle applies to each separately vested portion of the account balance.
Example 2. Jill Smith is a participant in the plan described in Example 1 and amounts deferred under the plan are credited with interest at an annual rate equal to the one-year Treasury bill rate (which, for the purpose of this example is assumed to be six percent per year). Jill Smith earns $150,000 a year and becomes a participant in the plan January 1, 1996. On January 1, 1999, Jill becomes vested in 20 percent of her interest under the plan. At that time, $47,754 (i.e., ($15,000 x 1.06(2)) + ($15,000 x 1.06) + $15,000) is credited to her account under the plan. Consequently, as of January 1, 1999, Jill has wages for FICA tax purposes of $9,550.80 (i.e., $47,754 x 20%). On January 1, 2000, Jill vests in another 20 percent of her account, which at that time has a balance of $65,619.24 (i.e., ($47,754 x 1.06) + $15,000). Although the amount in which Jill has a vested interest is now $26,247.70 (i.e., $65,619.24 x 40%), the FICA wages she has for the year do not equal the difference between that amount and the amount of wages she had as a result of participating in the plan in 1999. Rather, the income on the $9,550.80 that were wages in 1999 is exempt from FICA taxation in 2000. Thus, the amount of wages that Jill has in 2000 is $16,123.85 (i.e., ($26,247.70 - $9,550.80) - ($9,550.80 x .06)).
The IRS was alert to potential abuse of the statutory exclusion from FICA taxes of income on amounts previously subject to the taxes through the use of excessive interest or other investment performance standards. Thus, the proposed regulations state that not all amounts denominated as "income" under the terms of a plan are treated as such and impose limitations on the extent to which additional amounts credited to an employee's account are in fact treated as income exempt from FICA taxes. Specifically, an amount credited to a participant's account may be "income" if it is determined by reference to the actual rate of return for the year on a predetermined actual investment (regardless of whether any assets are actually invested in the investment) or, if no predetermined actual investment is specified, a reasonable interest rate (as determined by the IRS). If the earnings credited to an employee's account exceed whichever of these amounts is applicable, the employee will be taxed on wages equal to the excess of the amount credited to the account over the amount that would be determined using the mid-term applicable federal rate (AFR) for January 1 of the year. Presumably, the IRS will issue guidance on what will constitute a "reasonable interest rate" (e.g., Treasury bill rates, "GATT rates," i.e., the rates used to calculate certain lump-sum distributions from qualified pension plans, etc.). Until that time, however, an employer can be certain that an amount intended to be income will not be treated as wages only if an investment is specified in the plan or if interest is credited at a rate equal to or less than the AFR. In addition, the regulations make it clear that if earnings are credited at a rate equal to the better of the rates on two investments, no investment will be considered "predetermined." In this case, the AFR will again determine the amount treated as income for FICA tax purposes, and any excess will be treated as wages. Similarly, although the proposed regulations do not specifically say so, officials from Treasury and the IRS have stated that the AFR will also be the measure of the amount of income where a plan provides for income to be credited at a rate earned by a specific investment or, if greater, a specified rate of interest (even if the rate is reasonable).
Further, even if additional credits to a participant's account under an account balance plan are denominated as income and do not exceed the permissible amount, they will not be treated as income exempt from FICA taxation if the amounts with respect to which they purport to be income have not actually been taken into account for FICA tax purposes. For an amount to be "taken into account," the employer must pay the applicable FICA tax. If the employer has not done that, any amounts that would be treated as income - along with the underlying deferral - are subject to FICA tax when paid.
* Nonaccount Balance Plans. A "nonaccount balance plan" is defined as any arrangement that in not an "account balance plan." Generally, nonaccount balance plans will be defined benefit arrangements under which an employee is promised a specified amount at a specified time. Not all nonaccount balance plans, however, will resemble usual defined benefit pension plans, under which a participant is promised an amount related to his service with and compensation from the employer. Although the point is not made explicit in the proposed regulations, government officials have said that a plan is not an account balance plan if the participant's benefit does not include an interest component. The typical long-term incentive plan, under which a participant will receive a specified amount if the participant or the employer attains predetermined performance goals, generally does not include an interest element and, therefore not being an account balance plan, is a nonaccount balance plan.
The amount includable as FICA wages as a result of an employee's participation in a nonaccount balance plan is generally equal to the increase in the present value of his benefit under the plan over any present value previously treated as FICA wages. Any reasonable actuarial assumptions can be used to determine the present value of a benefit; in addition, certain assumptions that reflect the probability that all or a portion of a benefit will not be paid can be taken into account. The regulations recognize, however, that a certain portion of the increase in the present value of a benefit is attributable solely to factors related to the passage of time. (Because of the shortening of the discount period and because an individual's life expectancy decreases each year by less than a full year, the present value of a specified sum at the end of any year is greater than the present value of that sum as of the end of the previous year, assuming a constant interest rate assumption.) Consequently, the regulations treat this portion of the increase in the present value as income on amounts previously taken into account and, thus, as exempt from FICA taxation.
Example 3. Employer Y establishes in 1996 a nonaccount balance plan under which participants are entitled to receive, at age 65, a life annuity equal to two percent of "final average earnings" for each year of service. All participants are always fully vested in their benefits under the plan. Jane Jones is a participant in the plan who, as of December 31, 1996, is 60 years old and has 25 years of service and "final average earnings" of $100,000. Consequently, she is entitled to a receive a life annuity of $50,000 which using reasonable actuarial assumptions, has a present value of $375,000. Employer Y includes this $375,000 in Jane's wages subject to FICA tax and, as of December 31, 1997, Jane has "final average earnings" of $104,000, entitling her to a life annuity at age 65 of $54,080. Even though this life annuity has a present value, using the actuarial assumptions used at the end of the previous year, of $435,000, Jane does not have additional wages subject to FICA taxes of $60,000 (i.e., $435,000 - $375,000). Rather, Jane has FICA wages equal to the present value (using the same actuarial assumptions) of a life annuity of $4,080 (i.e., $54,080 - $50,000) beginning at age 65, or $33,000. The $27,000 difference between $60,000 and $33,000 is considered income on the $375,000 previously taken into account and, therefore, is exempt from FICA taxation.
Although the present value of an employee's benefit under a nonaccount balance plan can be determined at any time, uncertainties relating to future benefits (e.g., the form in which the benefit will be paid, the possibility that the benefit when paid will include some sort of early retirement subsidy, the amount of any benefit payable from an underlying qualified plan, etc.) can make this determination especially complicated. Accordingly, the regulations do not require that any amount under a nonaccount balance plan be taken into account for FICA tax purposes until the date on which it becomes "reasonably ascertainable." (This date is referred to in the regulations as the "resolution date.") An amount is considered "reasonably ascertainable" only if the sole actuarial or other assumptions needed to determine the amount deferred are interest, mortality and cost-of-living assumptions.
It is important to note that the rule delaying the recognition of wages for FICA tax purposes until the resolution date is a doubled-edged sword. On the one hand, it reflects the most administratively practicable approach; on the other hand, it has the potential for requiring a tremendous amount of wages to be taken into account in the first year that deferred amounts become reasonably ascertainable. Accordingly, the regulations allow an employer to elect to include an amount in an employee's FICA wages as of any earlier date on or after the time at which the relevant services have been performed and the employee's rights to the deferred amounts are vested. (This date is referred to in the regulations as the "early inclusion date.") If it is determined at the resolution date that the aggregate value taken into account on all early inclusion dates (plus income on that value) is less than the value of the benefit at the resolution date, the difference must be made up at that later date. If the aggregate amount taken into account on all early inclusion dates is greater than the value determined as of the resolution date, the employer will be able to claim a refund of the amounts overpaid, but only as long as the refund is otherwise available. Thus, if the resolution date occurs after the statute of limitations has run for the year including the early inclusion date, the employer will not be permitted to claim a refund for any overpayments of FICA taxes.
As previously noted, where an employer treats amounts as wages as of an early inclusion date and is then required to treat additional amounts as wages as of the resolution date, income on amounts taken into account prior to the resolution date are not wages as of the resolution date. The regulations specify that the income on the amounts previously taken into account is determined using interest rate and, where applicable, mortality assumptions that are reasonable as of the early inclusion date. This rule is not necessary an intuitive one. Because much time can pass between the early inclusion date and the resolution date, "reasonable" actuarial assumptions may have changed considerably. Moreover, because all relevant information is known as of the resolution date, it seems proper to use assumptions that are reasonable in respect of the entire period between the two dates. Perhaps this rule will be modified when the regulations are finalized.
Perhaps the most significant choice an employer is required to make under the proposed regulations is between waiting until the resolution date to treat deferred amounts as wages or taking them into account as wages as of an early inclusion date. The advantages of taking amounts into account as of an early inclusion date are the following:
* The employee probably has other wages in excess of the OASDI wage base, so that no deferred amount will be subject to this portion of the tax.
* The exclusion from wages of income on amounts previously taken into account gives rise to "inside build-up" within the plan that is free from FICA tax.
* The amount taken into account in any one period may be minimized.
The disadvantages, relative to waiting until the resolution date, are that -
* Expensive actuarial calculations are needed more frequently.
* There is a potential for the employer and employees to make unrecoverable overpayments.
As previously noted, where the resolution date occurs after the statute of limitations has run for the year including the early inclusion date, the employer will not be permitted to claim a refund for any FICA taxes it overpaid. Although it is impossible to make any universal assertions about which approach is more beneficial, in many cases the cost savings from reducing the number of actuarial calculations (and waiting until most factors needed to make these calculations are known) will outweigh the benefits of treating amounts as subject to FICA taxes as of an early inclusion date.
Withholding and Paying FICA Taxes. Generally, FICA taxes must be withheld and paid at the time the deferred amounts are required to be taken into account. Nevertheless, the proposed regulations allow a good deal of flexibility on these timing issues. First, the regulations provide a "rule of administrative convenience" pursuant to which an employer may withhold and pay taxes at any time before the end of the calendar year in which the amounts are required to be treated as FICA wages. In addition, if the amount of the FICA wage inclusion cannot be readily calculated by the end of the year, an employer may use the "estimated method" or the "lag method" to make the calculation.
Under the estimated method, the employer may make a reasonable estimate of the amount required to be taken into account and withhold and pay FICA taxes on these amounts by the end of the year. If the employer underestimates the wage inclusion, the shortfall can be treated as wages (1) in the year in which the amounts were deferred (and the employer must correct the Forms W-2, W-2c, and 941 for that year), or (2) during the first calendar quarter of the following year. Income on the shortfall to the date of withholding and payment of FICA taxes is not treated as wages subject to FICA tax. If the employer overestimates the wage inclusion, it can claim a refund for the overpayment.
Under the lag method, the employer can calculate the deferred amount and make the payment by its first deposit date after the close of the first calendar quarter of the next year. Unlike under the estimated method, income earned on the deferred amount through the date on which the FICA taxes are withheld and paid is treated as additional wages under the lag method. The proposed regulations are not entirely clear, however, on the extent to which this "income" is treated as wages. Is the income to be calculated from the date on which the amount was required to be taken into account (i.e., when the underlying services were performed or when any substantial risk of forfeiture lapsed), or is the income to be calculated from the last day of the calendar year? Technically, the "rule of administrative convenience" only requires that income from the last day of the calendar year be treated as wages. Moreover, this result is consistent with a rule that is intended to promote "administrative convenience"; if the rule were otherwise, the employer would be required to determine income from a date prior to the date as of which it is determining the amount of underlying wages.
While the regulations offer employers a number of choices (e.g., to treat an amount as wages as of the resolution date or as of an early inclusion date), it may be difficult for the employer to determine which option is preferable. With respect to the decision to use the estimated method or the lag method for withholding and paying FICA taxes, however, the choice for larger employers may be clear. Because employers that withhold and deposit more than $50,000 of employment taxes per year are required to deposit these taxes daily, they will gain little additional time under the lag method, and the cost of treating income on the deferred amount earned during the lag period as FICA wages could be significant. As a practical matter, therefore, most employers in this category will want to opt for the estimated method.
Transition Rules. The proposed regulations are generally effective for amounts deferred and benefits paid on or after January 1, 1997. For periods before that date, the regulations provide flexible transition rules. First, consistent with the interim guidance provided in Notice 94-96, the regulations provide that any determination of FICA tax liability prior to the effective date of the regulations will satisfy section 3121(v) if it is made in accordance with a reasonable, good-faith interpretation of the statute. (Of course, a determination that is made consistently with the proposed regulations will be considered to be based on a reasonable, good-faith interpretation.) More significantly, for any year for which the statute of limitations has not run, an employer who - using a reasonable, good-faith interpretation of the statute - made a determination of FICA liability for an amount deferred under or paid from a nonqualified deferred compensation plan that is inconsistent with the proposed regulations is given the opportunity to adjust its determination for that year. Additional transition provisions address situations in which employers either treated plans that are not nonqualified deferred compensation plans as subject to section 3121(v) or failed to treat nonqualified deferred compensation plans as subject to section 3121(v).
Although a detailed discussion of the transition rules is beyond the scope of this article, these rules merit two general comments. First, there are situations in which, under the transition rules, it would be advantageous to treat amounts as having been deferred and taken into account for FICA tax purposes in previous years. The regulations make it clear that no amount can properly be taken into account as wages subject to FICA taxes prior to the time that the relevant plan is established. Under the regulations, a plan will be treated as established only as of the latest of (1) the date on which it is adopted, (2) the date on which it becomes effective, or (3) the date on which the material terms of the plan are reduced to writing. Although a transition rule provides relief for plans that are adopted and effective, but as-yet unwritten, if benefits are to be paid from the plan after the effective date of the regulations, it is important that the plan's material terms be reduced to writing before the expiration of the transition period.
Second, an employer may generally revisit its determination of FICA liability for any year for which the statute of limitations has not run. 1993 is still an "open" year, and in 1993 there was still a cap on the amount of wages taken into account for purposes of the Medicare portion of the FICA taxes. Under this transition rule, then, it may be possible for employers to go back and treat as wages for that period amounts that were not previously so treated, thereby minimizing the extent to which amounts will be subject to the Medicare portion of the tax. To the extent that it is possible to do this, saving 2.9 percent of $135,000 for each affected employee may make taking advantage of an early resolution date cost-effective where it otherwise might not be.
Federal Unemployment Taxes
Proposed regulations were also issued under section 3306(r) of the Code, which sets forth for FUTA (i.e., federal unemployment tax) purposes the same rule as section 3121(v) does for FICA purposes. These regulations provide that the rules in the proposed regulations under section 3121(v) are applicable for the purposes of section 3306(r) as well.
The proposed regulations under section 3121(v) provide much-needed guidance on the application of employment taxes to nonqualified deferred compensation. Generally, the rules set forth in these proposed regulations are quite reasonable and accord employers significant flexibility. With careful analysis and planning, employers should be able to minimize the administrative burden, and perhaps the tax liability, in determining, collecting and remitting employment taxes with respect to nonqualified deferred compensation.
PAUL T. SHULTZ is a partner in the New York and Washington, D.C., offices of Sutherland, Asbill & Brennan, where his practice is concentrated in all areas of employee benefits law. Mr. Shultz received his A.B. in 1962 from Princeton University and his J.D., with distinction, in 1966 from Cornell Law School, where he was Managing Editor of Law Review and a member of Order of Coif and Phi Kappa Phi.
IAN A. HERBERT is an associate in the Washington, D.C., office of Sutherland, Asbill & Brennan, where his practice is also concentrated in all areas of employee benefits law. Mr. Herbert received his A.B. in 1982 from Washington University, his J.D. in 1985 from the University of Illinois, and his M.B.A. in 1987 from the Wharton School of the University of Pennsylvania.
(1) E.g., PLR 9051003 (Sept. 18, 1990). (2) Buffalo Bills, Inc. v. United States, 31 Fed. Cl. 794 (1994). (3) 1994-2 C.B. 564. (4) In setting forth this rule, the IRS essentially acquiesced to the holding in the Buffalo Bills case, in which the Claims Court applied a literal definition of the term "deferred." (5) To a certain extent, the IRS has coordinated the FICA rules with the rules governing an employer's deduction for deferred compensation. Generally, an accrual basis taxpayer is entitled to deduct amounts paid as compensation for services rendered in the year in which the services are performed. If the compensation is paid pursuant to a nonqualified deferred compensation plan, however, the employer is entitled to the deduction, in accordance with section 404(a)(5), only in the year in which the employee treats the compensation as taxable income. For the purpose of this rule, an amount is presumed to be paid pursuant to a nonqualified deferred compensation plan if it is paid more than two-and-a-half months after the end of the year in which the services giving rise to the payment were performed; an amount paid within this period is generally considered current, rather than deferred, compensation. This approach reflects an accommodation of the holding in the Buffalo Bills case and the position the IRS took in PLR 9051003, in which the IRS concluded that amounts will not be considered deferred compensation for purposes of section 3121(v) if they are not deferred compensation for purposes of section 404(a)(5). (6) In completing Forms W-2, employers must indicate, in Box 11, the amount "that was distributed or became taxable because the substantial risk of forfeiture lapsed" under a nonqualified deferred compensation plan. The instructions further state: Nonqualified plans include those arrangements traditionally viewed as deferring the receipt of current compensation. Accordingly, welfare benefit plans, stock option plans, and plans providing dismissal pay, termination pay, or early retirement pay are not nonqualified plans. (7) Individual accounts, however, need not be maintained for individual participants for the plan to be an account balance plan. It is sufficient if individual participants are entitled to a specified portion of a pool of assets that is maintained for all plan participants.
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|Author:||Herbert, Ian A.|
|Date:||Mar 1, 1996|
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