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Use of Healthcare-Account-Specific Debit Cards to Access Amounts in a Healthcare Account
Orrick, Herrington & Sutcliffe LLP 
Nov. 1, 2006
Excerpt: Unless and until the IRS liberalizes its position regarding the use of debit cards to access amounts in a Healthcare Account, employers should obtain assurance from their debit card provider that debit card services are being administered in accordance with Revenue Ruling 2003-43 and Notice 2006-69.
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