1Willis North America | May 2014

HRFocusHUMAN CAPITAL PRACTICE

May 2014 www.willis.com

HR CORNER2014 MARKS EXPANSION OF CALIFORNIA’S PAID FAMILY LEAVEBY MARINA A. GALATRO, PHR-CA

In 2002, California became the first state to extend disability compensation to cover individuals who take time off to care for an ill family member or to bond with a new child. On September 24, 2013, Governor Jerry Brown signed a bill extending California’s Paid Family Leave (PFL) program even further, to relatives beyond parents, spouses, children, and registered domestic partners.

Currently, the PFL program (also known as the Family Temporary Disability Insurance program) extends disability compensation benefits up to 55% of an employee’s average salary for up to six weeks within a 12-month period to individuals who take time off from work to care for a seriously ill child, spouse, parent, or domestic partner, or to bond with a new child. California’s PFL program is a wage replacement benefit administered by the Employment Development Department’s (EDD) State Disability Insurance (SDI) program and funded by employee’s payroll tax deductions.

Effective July 1, 2014, California’s PFL program will include workers who take time off to care for seriously ill grandparents, grandchildren, siblings and in-laws.

The PFL program is not protected time off. PFL is often confused with time off because of the word “leave” in its title. It is not a leave of absence program but a wage replacement benefit program.

Employees requesting time off from work that does not fall under the PFL program should follow their company’s leave of absence policy. Eligible employees may apply for Paid Family Leave by visiting the EDD’s website at www.edd.ca.gov.

For employers with employees in CA, the Paid Family Leave, DE 2511 brochure is one of many notices and documents required at the time of hire. This brochure must also be provided to employees who request leave for a seriously ill family member or to bond with a new child. Note: the Paid Family Leave brochure has not yet been updated to reflect the new change.

HR CORNER2014 Marks Expansion of California’s Paid Family Leave ...........1Report Reveals Wide Disparity of Generational Attitudes Towards Work-life Balance .........................................................2

HEALTH OUTCOMESDoubling the Yield.......................................................................3

LEGAL AND COMPLIANCEAnnual Deductible Limits for Small Group Plans Repealed .......4IRS Issues Additional Guidance on Health FSA Carryover, HSA Eligibility ..............................................................................5

SINCE YOU ASKEDHow Do Rules Limiting Waiting Periods Apply to Employees Currently in a Waiting Period? ..................8

WEBCASTS .......................................................................9

CONTACTS ...................................................................... 10

Willis North America | May 20142

HR Corner – continued from page 1

REPORT REVEALS WIDE DISPARITY OF GENERATIONAL ATTITUDES TOWARDS WORK-LIFE BALANCE THIS ARTICLE PROVIDED BY BLR

A new survey of parents about the impact their generational status has on their own work-life choices and satisfaction has been released by the Working Mother Research Institute and reveals a disparity of attitudes.

Commissioned to mark the 35th anniversary of Working Mother magazine, the “Working Mother Generations Report” found the greatest disparity in generational attitudes on work-life issues lies between Millennials (born 1981-2000) and Baby Boomers (born 1946-1964).

Highlights of the full research report, which is sponsored by SC Johnson, include:

� 71% of Millennials says they are satisfied with their choice to be a working or stay-at-home parent vs. 59 percent of Boomers.

� 75% of Millennials are satisfied with their partners’ contribution to the family’s finances, while only 58% of the Boomers are.

� Millennials score highest (60%) in believing one parent should stay home to care for the children, over Generation X (50%) and Boomers (55%).

� 62% of Millenials believe that when a mother works outside the home, it sets a positive example for her children (62%), followed by Gen X (57%) and Boomers (55%).

Carol Evans, president of Working Mother Media, says, “This report finds fascinating differences among the generations, with parents in each group having their own ideas about the best ways to manage career and family obligations. These are important differences employers should note as they tailor work life policies to benefit the widest range of working parents.”

Views vary on work life stress by generation:

� More than half of all Millennials say that flex causes work to interfere with family time vs. only a quarter of Boomers.

� Millennials report working the same average hours—7.8 daily—as the other generations, but roughly half say they “cannot get away from work.”

� Millennials are much more likely to say they would prefer to work even if they did not have to financially (47%) vs. Gen X (37%) and Boomers (36%).

� Gen X is the least likely generation to say they’re fulfilling a higher purpose through work than just making money (13 percentage points lower than Millennials and 8 percentage points lower than Boomers).

Generation X has a “front row seat to work life tensions,” says Working Mother Research Institute Director Jennifer Owens. “This is not that surprising, considering that this generation is striving to move into higher positions at work, while also working to guide their children through homework, after-school activities and everything else, with an eye towards college. Meanwhile, Boomers are thinking about their own future changes, including retirement, and are mostly likely to be dealing with elder care issues with their parents.”

3Willis North America | May 2014

HEALTH OUTCOMESDOUBLING THE YIELD Why Employers Should Focus on Both the Health and the Productivity of Their WorkforceBY RONALD S. LEOPOLD, M.D., M.B.A., M.P.H.

Even if they were to get out of the health care business, employers never will be out of the worker productivity business, even though they are sending up red flares the way they did more than two decades ago around retirement benefits.

Instead of perpetuating the “we will pay for it all, no matter what” approach, employers are rewriting the rules and shifting costs and risks in health coverage to employees. Today’s message is, “We will pay good money for fundamental value in health costs, but in the end it’s your health, your life and your path.” The shift from defined benefit to defined contribution is on, and the Affordable Care Act is a powerful catalyst for it.

A DIFFERENT OPPORTUNITY There is a business value to having a healthier working population is an emerging axiom for American businesses that is now being recognized by employers around the globe. In most nations, the interest in health and wellness is growing because it’s smart business. A healthier workforce is more productive. Companies operating in such countries as Brazil, Poland and South Korea understand this. They don’t pay for health care (because the government provides it), but they’re increasingly interested in improving the health and wellness of their employees.

How do products and services that touch human capital affect worker productivity? If a company’s value proposition includes better health, it is undoubtedly touting a reduction in health care costs. But what about worker productivity?

THE BUSINESS CASEThere is a genuine business value to having a healthy working population. According to a recent Integrated Benefits Institute analysis, employees’ poor health and its impact on productivity costs the U.S. economy $576 billion per year.1 The estimated costs are categorized as follows:

� Medical and pharmacy account for 40% ($232 billion per year). This includes workers’ compensation, employee group health medical treatments, employee group health pharmacy treatments, and workers’ compensation medical costs.

� Wage replacement costs account for 20% ($117 billion per year). This includes incidental absence due to illness, short-term disability, long-term disability, and workers’ compensation income payments.

� Lost productivity represents 40% ($227 billion per year). This reflects business costs around absence due to illness or to “presenteeism.” (Presenteeism is the decrease in a worker’s productivity as a result of coming to work but not performing optimally. This can occur due to a medical symptom slowing down workflow, a medicine’s side effect impacting output quality, or preoccupation with a condition affecting customer service.)

In other words, employers, their carriers and their third-party vendors have focused on demonstrating return on investment (ROI) through reducing health care costs. Bending the health care cost trend curve has become the mantra – often the sole mantra – of innovations and solutions in the health and wellness space.

The landscape is changing. As employers shift health care costs and risks, the employer price tag will become more contained and more predictable. The ROI from reductions in medical costs still will be important – just relatively less important, as individual employees become more responsible for their own health care and related costs.

Continued on page 41 Integrated Benefits Institute, 2012. Reported in Forbes Sept. 12, 2012.

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Continued on page 6

LEGAL AND COMPLIANCEANNUAL DEDUCTIBLE LIMITS FOR SMALL GROUP PLANS REPEALED

President Obama recently signed into law the “Protecting Access to Medicare Act of 2014.” While the legislation’s primary purpose was to delay changes to the formula used to determine the amounts Medicare pays health care providers for services, it also contained provisions not directly related to Medicare. Of interest to small employers was the legislation’s elimination of the annual deductible limits imposed under the health care reform law. The Patient Protection and Affordable Care Act (PPACA) limited the annual deductibles of health plans offered in the small group insurance market, starting in 2014, to $2,000 for self-only coverage or $4,000 for coverage other than self-only coverage. This change should give small employers greater flexibility in designing the plans they offer to their employees.

A small group market plan is a plan with up to 100 employees on average, or up to 50 employees on average for those states that adopted that lower threshold. The Department of Health and Human Services (HHS) had interpreted this law as being limited to non-grandfathered insured small group market plans. This provision was not applicable to any employer-sponsored self-funded plan, grandfathered plan or insured large group market plan.

The repeal of the deductible limits is effective “as if included in the enactment” of PPACA, which means it is treated as if it had never been enacted. Please note that only the requirement under PPACA was repealed; similar requirements under state law are not affected.

Health Outcomes – continued from page 3

What will become more important are the time costs and the business costs for employers around what happens as employees adjust to this new paradigm.

Absenteeism (people missing work – the time value of lost health) creates direct costs that can (and should) be measured. How health transactions are managed and measured substantially impacts the time of employees, specifically whether they can work or whether they are paid for a day’s work but cannot come to work because of a medical condition. Delays in health care and inefficiencies in the health care system present tremendous costs to employers.

While many companies measure and monitor these costs (short-term disability data, absence data and workers’ compensation data), they are rarely factored into the management or ROI calculations of health care initiatives.

CHANGING TOMORROWWhile many people talk a good game around health and productivity, very few come to the table with well-thought-out strategies around the time costs and the business costs created by lost health. Looking to the future, however, it is critical to understand that the relationship between health and productivity is real, and it is quantifiable. As we enter an era that inevitably will be changed by health care reform and a new business environment, those who integrate this perspective into their business operations likely will see increased ROI in a side of the employee wellness equation that until now has not been considered.

5Willis North America | May 2014

Continued on page 6

Legal and Compliance – continued from page 5

IRS ISSUES ADDITIONAL GUIDANCE ON HEALTH FSA CARRYOVER, HSA ELIGIBILITYThe Internal Revenue Service (IRS) Office of Chief Counsel advises the IRS on questions of tax and issues of interpretation concerning day-to-day administration of benefit plans. The Chief Counsel recently issued two memoranda that answer questions regarding health flexible spending account (FSA) carryovers, health savings account (HSA) eligibility, and the correct handling of improper health FSA reimbursements. Any guidance from the Chief Counsel’s office constitutes official guidance. Background

Plan sponsors offering a health FSA must maintain a cafeteria plan allowing employees to make pre-tax contributions to the health FSA. This ability to make pre-tax contributions does have strings attached, however. For example, cafeteria plan rules make it impermissible for the plan to defer compensation (paying for benefits in one year, but collecting the benefits in the next year). The FSA use-or-lose rule, which generally provides that contributions not used to reimburse qualifying expenses incurred during the plan year are forfeited, has been enforced for years because of this prohibition on deferred compensation.

Though the use-or-lose rule is still in place, since 2005 there has been a slow departure from the inflexibility of the rule, and health FSA rules have therefore been slowly loosened. In 2005, the IRS allowed plan sponsors to implement a grace period within the health FSA, permitting participants to “spend down” their health FSA account balances in the first two and a half months of the following year. This modification helped relieve the sting of the use-or-lose rule but at the same time limited those with a health FSA balance during the grace period from establishing an HSA in conjunction with a high deductible health plan. (Coverage under the grace period may disqualify one from making a tax-deductible HSA contribution for months in which the extension period overlaps coverage under the high deductible health plan, unless the individual’s health FSA account has been fully depleted prior to [or coincident with] the end of the health FSA plan year.)

In 2013, the IRS further modified the use-or-lose rule (via IRS Notice 2013-71) by allowing plan sponsors to extend an additional option to those enrolled in a health FSA. Plan sponsors can now implement a health FSA $500 carryover feature that allows participants to carry over up to $500 of otherwise forfeitable funds

(the amount remaining at the conclusion of the claim run-out period) to the next plan year. The amount carried over can be used by health FSA participants to pay for any reimbursable medical expenses incurred at any time during that year.

The carryover feature does not impact the $2,500 (indexed) annual salary reduction limit applicable to health FSAs, so participants are able to make health FSA elections without considering the amount of money that will be carried over from the prior plan year. Consequently, one might elect to contribute the maximum $2,500 to a health FSA and be able to add to that election up to $500 in carryover funds from the prior year’s health FSA.

Plan sponsors considering implementing a health FSA carryover have discretion concerning a number of factors:

1. Whether to allow the maximum $500 carryover amount or a lower amount – Whatever amount is designated by the plan (the carryover amount is limited by the amount that will actually be forfeited by a participant, and the maximum carryover amount is $500) would be applied to all health FSA participants.

2. Whether to apply an “ordering rule” to the use of the carryover funds – A plan sponsor may require that reimbursements of all claims incurred in the current plan year be reimbursed from current salary reduction amounts and only permit use of the carryover funds after the current year’s health FSA election has been exhausted.

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Legal and Compliance – continued from page 5

3. When to amend the cafeteria plan document – If the health FSA provides for a grace period, then the $500 health FSA carryover provision is not available and cannot be used in the year when a grace period exists. However, a plan sponsor may remove the grace period element of its health FSA so that the $500 carryover can apply in the following plan year. In this case, the plan sponsor must amend the plan document to eliminate the grace period before the end of the plan year from which amounts will be carried over and communicate the change to employees (since they may otherwise count on the existence of the grace period in order to incur additional medical expenses).

Under IRS Notice 2013-71, sponsors adopting an amendment to add the $500 FSA carryover must do so on or before the last day of the plan year from which amounts can be carried over. Plan sponsors adding a carryover provision for the 2013 plan year (i.e., to permit carryovers into the 2014 plan year) have until the last day of the 2014 plan year to adopt an amendment (provided that the plan is operated in accordance with the guidance and participants are informed of the carryover provision).

Latest Guidance

The IRS Chief Counsel’s recently issued Memorandum No. 201413005 outlines official IRS understanding of various questions related to health FSA carryover funds as well as an individual’s eligibility for an HSA.

IRS Notice 2013-71, as discussed above, failed to address how carryover funds from a general purpose health FSA would affect one’s eligibility to contribute to an HSA during the year when the carryover FSA funds would also be available. The Memorandum answers seven questions on this topic:

1. General purpose FSA carryovers make participants ineligible for an HSA in the next year. An individual covered by a general purpose health FSA will not be permitted to make contributions to an HSA in the next year if the individual has access to funds carried over from the prior year’s general purpose health FSA.

2. The existence of any general purpose health FSA carryover funds makes an individual ineligible for an HSA during the entire health FSA plan year. Even in cases where the amount of the health FSA carryover is exhausted early in the FSA plan year, the individual is ineligible to contribute to an HSA during that FSA plan year.

3. A participant may carry over a general purpose health FSA balance and elect to incorporate those funds into an HSA-compatible health FSA. There is no requirement that general purpose health FSA carryover funds be placed into a general purpose health FSA (which would make one ineligible for an HSA).

4. A participant carrying over a general purpose health FSA balance into an HSA-compatible health FSA may fully contribute to the HSA during the year as long as that individual is otherwise an eligible HSA participant.

5. Automatic carry over to an HSA-compatible FSA is possible. If a cafeteria plan offers both a general purpose health FSA and an HSA-compatible FSA, the plan may automatically deposit the carryover funds into the HSA-compatible FSA if the individual is enrolled in a high deductible health plan.

6. Individuals may decline carryover in order to participate in an HSA in the following plan year. If one participates in a general purpose health FSA (and the balance will be automatically carried over by the plan sponsor), one may make an election prior to the next plan year, to either decline or waive the carryover. This will allow the individual to contribute to an HSA the following year, assuming that the individual is otherwise eligible to participate in an HSA. This is an option when the plan sponsor does not offer an HSA-compatible FSA that could receive the prior year’s health FSA carryover balance.

7. General purpose health FSA balances may be carried over to an HSA-compatible FSA in the next year; however, the amount carried over to the HSA-compatible FSA will be determined after the run-out period has been exhausted for the general purpose FSA.

Continued on page 5

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The IRS Chief Counsel also issued Memorandum No. 201413006, which outlines the rules for how a plan sponsor is required to correct any “improper payments,” such as non-substantiated claims and claims that are not for qualified medical expenses. The memo answers three questions on this topic:

1. In the case of an improper payment under a health FSA, the plan sponsor (or the third-party administrator on behalf of the plan sponsor) may follow the corrective procedures outlined for improper payments through a debit card. That corrective process includes the following steps:

a. Debit card is deactivated and future reimbursements from the account will be processed after the employee provides proof of each expense

b. The plan sponsor must demand that the employee repay an amount equal to the improper payment

c. The employer withholds the amount of the improper expense from the employee’s pay or other compensation

d. The employer may apply an offset against future, substantiated claims submitted by the employee

e. The employer may treat the improper payment as any other business indebtedness (forgiveness of uncollectible business indebtedness)

2. The employer may follow the above steps in any order that is consistently applied to all participants in the employer’s health FSA. However, treating the improper payment as any other business indebtedness may only be done after all other options have been pursued by the employer, and forgiving the debt should be an exception rather than the rule for improper health

FSA reimbursements; in these cases, the improper payment will be taxable to the employee. The correction attempts should be conducted within the plan year in which the improper payment was made; when the improper payment has been recouped, that amount will be immediately available to reimburse other claims incurred during the plan year (or the amount can be carried over to the next year if the plan sponsor has adopted a carryover provision for health FSA balances).

If the correction attempts cannot be or were not applied within the plan year in which they were made, then the employer should treat the improper payment as any other business indebtedness.

3. When all attempts to collect the improper payment have failed, the employer is left with forgiving the uncollectible indebtedness. In that case, the improper payment should be reported by the employer on the employee’s W-2 as taxable wages, and the amount will be subject to withholding for income tax, FICA and FUTA. The amount is reported in the taxable year in which the indebtedness is forgiven.

Legal and Compliance – continued from page 6

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SINCE YOU ASKEDHOW DO RULES LIMITING WAITING PERIODS APPLY TO EMPLOYEES CURRENTLY IN A WAITING PERIOD?

Recently, the National Legal and Research Group (NLRG) was asked whether an employer-provided group health plan could continue to apply a pre-2014 waiting period to eligible employees who had not yet met the plan’s requirement when it becomes subject in 2014 to the mandate limiting waiting periods to no more than 90 days. Final regulations, recently issued by the agencies responsible for implementing the health care reform law (the Departments of Treasury, Labor and Health and Human Services), provide guidance on this issue.

Background

Under the 90-day waiting period rule, a group health plan cannot apply a waiting period that exceeds 90 days. Individuals who are otherwise eligible cannot be required to wait more than 90 days before their health coverage becomes effective. All calendar days are counted beginning on the enrollment date, including weekends and holidays. A waiting period is the period that must pass before coverage for an employee or dependent who is otherwise eligible to enroll in the plan can become effective. Being otherwise eligible to enroll in a plan means having met the plan’s eligibility conditions. The requirement applies to group health plans (both grandfathered and non-grandfathered) as of the first day of the plan year beginning on or after January 1, 2014.

Application of New Requirements to Employees in Existing Waiting Periods

The preamble to the final regulations states that, for employees who are in the middle of a waiting period as of the date that the 90-day waiting period rule becomes effective in 2014, a plan cannot impose a waiting period longer than 90 days, as measured from the date that the employee’s waiting period started before the beginning of the 2014 plan year. For example, if an employee has reached the 80th day of the waiting period as of May 30, 2014 under a plan with a plan year that starts June 1 and a pre-June 1, 2014 waiting period of 120 days, the employee’s coverage must be effective June 9, 2014, not July 9, 2014. In effect, the employee must receive credit for “time served” under the old waiting period when the new waiting period is applied beginning in 2014.

In summary, when implementing the 90-day waiting period guidelines, employers should be careful to design the waiting period aspect of their plans in order to comply with the rules as of the date those rules become effective for their plans in 2014.

9Willis North America | May 2014

HEALTH CARE REFORM: WHAT ARE YOU DOING,WHAT ARE OTHER EMPLOYERS DOING, WHAT’S NEXT?

Tuesday, May 20, 2014 2:00 PM Eastern

Presented by: Rebecca Knoll Lawrence, JDNational Legal and Research GroupHuman Capital Practice

Emily FerreiraBenchmarking and Survey ConsultantHuman Capital Practice

Willis has recently completed its annual Health Care Reform survey. This webinar will highlight some of the key findings of the survey and help you understand the opinions of other employer groups as it relates to the impact of health care reform as well as some of the strategies utilized by employers in complying with the law.

During this session, participants will learn:

� What steps employers have taken so far in efforts to comply with PPACA requirements

� How employers are addressing rising health care costs, including cost-shifting and exploration of defined-contribution approaches

� What strategies employers have implemented or plan to implement in the near future around Health Care Reform

To RSVP, click here.

NOTE: Advance RSVP is required to participate in this call. Registration ends 1 hour prior to the call start time.

Both of the above programs have been approved for 1 recertification hour toward PHR, SPHR and GPHR recertification through the Human Resource Certification Institute (HRCI). For more information about certification or recertification, please visit the HRCI homepage at www.hrci.org.

WEBCASTSCOMPREHENSION AND EDUCATION: COMMUNICATING HEALTH CARE REFORM

Tuesday, June 17, 2014 2 PM Eastern

Presented by:Holly Flontek, MHS, GBASenior Communication ConsultantHuman Capital Practice

Affordable Care Act, Obamacare, Health Insurance Marketplaces, Exchanges, Minimum Essential Coverage…is your head spinning yet? Health care reform lingo can be difficult to keep up with, so how should you communicate these topics to your employees without sounding like a professor?

During this session, we will discuss:

� The complex communication requirements of Health Care Reform

� How to continue the Health Care Reform conversation with employees

� Best practices to educate employees on benefit programs and how health care reform can assist with engagement

To RSVP, click here.

NOTE: Advance RSVP is required to participate in this call. Registration ends 1 hour prior to the call start time.

Willis North America | May 201410

NEW ENGLAND

Auburn, ME207 783 2211

Bangor, ME207 942 4671

Boston, MA617 437 6900

Burlington, VT802 264 9536

Hartford, CT860 756 7365

Manchester, NH603 627 9583

Portland, ME207 553 2131

Shelton, CT203 924 2994

NORTHEAST

Buffalo, NY716 856 1100

Morristown, NJ973 539 1923

Mt. Laurel, NJ856 914 4600

New York, NY212 915 8802

Norwalk, CT203 523 0501

Radnor, PA610 254 7289

Wilmington, DE302 397 0171

ATLANTIC

Baltimore, MD410 584 7528

Knoxville, TN865 588 8101

Memphis, TN901 248 3103

Metro DC301 581 4262

Nashville, TN615 872 3716

Norfolk, VA757 628 2303

Reston, VA703 435 7078

Richmond, VA804 527 2343

Rockville, MD301 692 3025

SOUTHEAST

Atlanta, GA404 224 5000

Birmingham, AL205 871 3300

Charlotte, NC704 344 4856

Gainesville, FL352 378 2511

Greenville, SC704 344 4856

Jacksonville, FL904 562 5552

Marietta, GA770 425 6700

Miami, FL305 421 6208

Mobile, AL251 544 0212

Orlando, FL407 562 2493

Raleigh, NC704 344 4856

Savannah, GA912 239 9047

Tallahassee, FL850 385 3636

Tampa, FL813 281 2095

Vero Beach, FL772 469 2843

MIDWEST

Appleton, WI800 236 3311

Chicago, IL312 288 7700

Cleveland, OH216 861 9100

Columbus, OH614 326 4722

Detroit, MI248 539 6600

Grand Rapids, MI616 957 2020

U.S. HUMAN CAPITAL PRACTICE OFFICE LOCATIONS

KEY CONTACTS

11Willis North America | May 2014

Milwaukee, WI262 780 3476

Minneapolis, MN763 302 7131763 302 7209

Moline, IL309 764 9666

Pittsburgh, PA412 645 8506

Schaumburg, IL847 517 3469

SOUTH CENTRAL

Amarillo, TX806 376 4761

Austin, TX512 651 1660

Dallas, TX972 715 2194972 715 6272

Denver, CO303 765 1564303 773 1373

Houston, TX713 625 1017713 625 1082

McAllen, TX956 682 9423

Mills, WY307 266 6568

New Orleans, LA504 581 6151

Oklahoma City, OK405 232 0651

Overland Park, KS913 339 0800

San Antonio, TX210 979 7470

Wichita, KS316 263 3211

WESTERN

Fresno, CA559 256 6212

Irvine, CA949 885 1200

Las Vegas, NV602 787 6235602 787 6078

Los Angeles, CA213 607 6300

Phoenix, AZ602 787 6235602 787 6078

Portland, OR503 274 6224

Rancho/Irvine, CA562 435 2259

San Diego, CA858 678 2000858 678 2132

San Francisco, CA415 291 1567

San Jose, CA408 436 7000

Seattle, WA800 456 1415

The information contained in this publication is not intended to represent legal or tax advice and has been prepared solely for educational purposes. You may wish to consult your attorney or tax adviser regarding issues raised in this publication.

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