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Survey of Employee Benefits Issues in a Global Economy;

September 30 Response Date

The IRS Advisory Committee on Tax Exempt and Government Entities (TE/GE) (the “ACT”) is undertaking a study to identify international and cross-border activities, issues, challenges, impediments and barriers in connection with the design, coverage, portability, and tax administration of US employee retirement (qualified and non-qualified) and fringe benefit plans.

As part of this effort, the ACT is particularly interested in the views of stakeholders, such as employers, administrators, trustees, custodians, practitioners and consultants regarding these issues.

While all input is welcome, the ACT is particularly interested in the challenges, barriers, and concerns, in connection with the following categories:

1) US employee benefit plans covering employees working outside of the United States, whether expatriates, seconded employees, leased employees, non-resident aliens or others with US and/or foreign compensation.

2) US employee benefit plans covering foreign nationals, green card holders, resident aliens, or others on temporary visas or assignments (such as clergy, ambassadors, speakers) working in the United States.

3) Coverage issues, such as controlled groups and separate lines of business, compensation definitions and discrimination testing, involving US subsidiaries with foreign parents or US companies with foreign operations.

4) Reporting, withholding and other special issues relating to Puerto Rico and other US possessions and territories, after Rev. Rul. 2008-40.

5) Reporting and withholding on contributions and distributions, double taxation, treaties, rollovers and other tax related issues.

To shape the direction of the ACT’s further analysis and recommendations, we would appreciate your input by September 30, 2008. In the space provided below, please enter all information that you feel would be helpful. If you would be willing to participate in further discussion by conference call or attend a stakeholders’ meeting in Washington DC in October 2008 or January 2009, please indicate your interest and provide contact information.

After you have entered your comments below (in this Microsoft Word document), please send the revised document to the ACT on or before September 30, 2008 by emailing it to susan.diehl@

As members of the ACT, we greatly appreciate your assistance with this project.

|Susan D. Diehl |(215) 444-9812 |

|Dodi Walker Gross |(412) 288-4132 |

|G. Daniel Miller |(202) 887-5711 |

|Susan P. Serota |(212) 858-1125 |

|Michael S. Spickard |(330) 644-2044; ext 201 |

|Marcia S. Wagner |(617) 357-5200 |

Please enter comments below – no limit as to length; include as many pages as you’d like -- and send the revised document to susan.diehl@ on or before September 30, 2008. Thank you!

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