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accrual rates ADEA age-weighted agency law aggregated allocation alternative amendment annuity apply basis benefits provided benefits test cafeteria plan Code Sec compliance corporation cost Court deduction deferred compensation defined benefit plan defined contribution plan determination letter disability early retirement window election eligible employee benefit plans employer-provided benefit employment ERISA excess benefits executive compensation factor federal formula FTC 2d H health coverage health plans highly compensated employees independent contractor individual limited ment minimum NHCEs non-excluded nondiscrimination tests nonhighly compensated employees nonqualified option participants payments pension plan percentage perform period plan benefits plan year beginning plan's ployee Private Letter Rulings prohibition purposes Rabbi Trust reasonable accommodation received regulations Rept requirements Rev Proc rules safe harbor satisfy secular trust separate spouse target benefit taxable taxpayer testing day tion treated unfunded waiver worker