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Additional Guidance on Retiree Drug Subsidy from IRS and CMS
Deloitte 
Sept. 27, 2005
Excerpt: Employers that have transferred excess pension assets to a special account to fund retiree medical benefits can receive the 28 percent retiree drug subsidy (RDS) and still comply with the IRC § 420(c)(3) minimum cost requirement, according to Revenue Ruling 2005-60. The revenue ruling holds the RDS is not taken into account in computing the applicable employer cost for purposes of the minimum cost requirement.
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