PPACA DETERMINATION OF FULL-TIME EMPLOYEES – INTERIM SAFEHARBOREmployers have been anxiously awaiting guidance on how to determine full-time status for theiremployees under the Patient Protection and Affordable Care Act (PPACA) – a determinationcentral to the “pay or play” and “affordability” mandates under PPACA and necessary for manyemployers in their planning.

BACKGROUND

Beginning in 2014, PPACA requires employers with 50 or more full-time employees (or theequivalent) to offer affordable health coverage that meets minimum requirements to all full-timeemployees or be subject to potential penalties.

The IRS and Department of Labor issued long-awaited interim guidance on August 31, 2012 toassist employers with their implementation. Notices 2012-58 and 2012-59 (also referred to bythe DOL as DOL Technical Release No. 2012-02) offer safe harbors (with new nomenclatureof course) for employer determinations of whether an employee is full-time for purposes of thepay or play and affordability mandates under PPACA and the application of the 90 day maximumwaiting period. The guidance was not issued as regulations so it does not have the force of law.The agencies have solicited additional public comments. There will likely be changes to the rulesafter the appropriate administrative process is completed.

Employers can rely on the safe harbor until at least the end of the 2014 plan year. In fact, if thestandard measurement periods (see below for more explanation) extend far enough into thecalendar year, the safe harbor may apply beyond the 2014 plan year. Employers that use the safeharbor will have some certainty that their determinations of full-time status will be respected.Note that the guidance is not mandatory but optional. Therefore, employers who find these rulestoo onerous can use other rules that meet the general requirements under the statute(presumably under a reasonable, good faith standard) at least until regulations are published.

Like much of the guidance on PPACA from the federal agencies, there is both good and bad newsfor employers and their administrative staffs.

FULL-TIME EMPLOYEE DETERMINATION

The notice permits employers the option to use a look-back period of up to 12 months todetermine whether new variable-hour employees or seasonal employees are full-timeemployees, without being subject to a penalty under §4980H of the Internal RevenueCode (IRC).

HUMAN CAPITAL PRACTICEALERT:HEALTH CARE REFORM BILLOctober 2012 www.willis.com

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PAY OR PLAY MANDATE IN THE IRC

Section 4980H of the Internal Revenue Code was added by PPACA and requires largeemployers (those with the equivalent of 50 or more full-time employees) to offer“affordable,” “minimum essential coverage” or pay a penalty. The penalty is oftenreferred to as the “pay or play” penalty, but the IRC refers to this as the “sharedresponsibility” requirement.

� If an employer with 50 or more full-time employees (or the equivalent) fails to offer“minimum essential coverage” to even one full-time employee, and that oneemployee obtains coverage via a state-based exchange, and the individual receivestax credits for the purchase of that coverage, the employer is subject to an annualpenalty of $2,000 for all full-time employees (less the first 30). The penalty isdetermined monthly and applies to all full-time employees, whether or not they havecoverage under the employer-sponsored plan.

� If an employer offers “minimum essential coverage” to all full-time employees, butthe coverage is not “affordable,” the employer is subject to a penalty of $250 permonth for each full-time employee (annually $3,000) who was not offered“affordable” coverage, obtains coverage via a state-based exchange and receives taxcredits for the purchase of that coverage. Affordability means that at least onecoverage option that meets the minimum essential benefits requirements has anemployee contribution for employee only coverage of no more than 9.5% of theemployee’s household income. Here, there is an aggregate maximum penalty of$2,000 times all full-time employees (less the first 30). Employers have rightly askedhow they can be expected to know the employee’s household income to make anaffordability determination. In response, the IRS issued a safe harbor that permits anemployer to make a determination using the employee’s federal taxable wages in Box1 of the W-2. While that adds some certainty in administration, it will likely understateor overstate the actual household income, sometimes substantially.

ONGOING EMPLOYEES

EMPLOYERS SELECT THE STANDARD MEASUREMENT PERIODOngoing employees are those that have been working for the employer for at least one“standard measurement period.” Each employer may establish a standard measurementperiod of three to 12 months to determine full-time status. The employer can use a calendaryear, or any other start and end dates for the standard measurement period, as long as thedetermination is made on a uniform and consistent basis for all employees in the samecategory (See: Permitted Employee Categories for Measurement Periods).

The determination is made on an individual basis. So, an employer who restricts eligibilityto full-time employees must count hours for all employees who may average less than 30hours a week.

IF THE EMPLOYEE IS A FULL-TIME EMPLOYEE DURING THE STANDARDMEASUREMENT PERIODOnce the employer determines the standard measurement period, the employer willdetermine if an employee worked an average of 30 hours per week during that period. If so,then the employer must treat the employee as a full-time employee during the subsequent“stability period” regardless of the number of hours worked during the stability period. Forthis purpose, the stability period must be at least six months but can be no shorter than thestandard measurement period that applied to that employee.

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IF THE EMPLOYEE IS NOT A FULL-TIME EMPLOYEEDURING THE STANDARD MEASUREMENT PERIODIf the employer determines that an employee has averaged fewerthan 30 hours per week during the standard measurement period andis therefore not a full-time employee, then the employer can treatthat employee as a part-time employee during the subsequent“stability period” regardless of the number of hours worked duringthe stability period. In this circumstance, the stability period can beas long as the standard measurement period but no longer.

PERMITTED EMPLOYEE CATEGORIES FORMEASUREMENT PERIODS

The permissible categories of employee for this purpose are:

1) Collectively bargained (i.e., union) employees and non-collectively bargained employees

2) Salaried and hourly employees3) Employees of different entities (such as different subsidiaries)4) Employees located in different states

Other categories of employees might also qualify (such asemployees in different divisions); however, the notice only identifiesthese four categories as qualifying for the safe harbor.

Employers who want to minimize the number of full-timeemployees will likely use separate categories.

For many employers, a 12-month measurement period would resultin the fewest number of full-time employees as that would requirethe most consistent status over a long period of time. However, itwould also result in a longer stability period for those employeesdeemed full-time during the measurement period (meaning thatcoverage would have to be offered even if they worked fewer hoursduring the stability period). For other employers, a shortermeasurement period may be the better option, since it will lead tothe shortest stability period for those employees deemed full-time.Retail operations, or perhaps a ski resort, where activity is highlyseasonal, are examples of employers who might benefit from ashorter measurement period.

All employers who restrict eligibility to full-time employees shouldstart tracking hours and reviewing employment patterns in order toidentify the measurement and stability periods that best meet theirneeds and objectives.

No guidance is provided about individualswho might move from one category toanother; however, a conservativeinterpretation would apply the measurementperiod that has the more favorable result withregard to eligibility for coverage.

ADMINISTRATIVE PERIODIn order to make a determination of theemployee’s status AND have time toadminister the plan properly based on thatstatus, the guidance provides up to a 90-dayadministrative period safe harbor AFTER thestandard measurement period. However, itwill have to overlap with the prior stabilityperiod in order to prevent gaps in coverage(assuming the individual was previously full-time during that stability period).

THE FOLLOWING EXAMPLE IS PROVIDED BY THEGUIDANCE: The Acme Co. has a 12-monthstability period from January 1 to December 31,2014. Based on prior standard measurementperiods, the employees who are full-time havecoverage during that period while part-timeemployees do not. The standard measurementperiod runs from October 15, 2012 to thefollowing October 14, 2013. That permits Acmeto have an administrative period between theend of the standard measurement period andthe next stability period that follows. Both thestandard measurement period and the stabilityperiod can each be 12 months. Employeeswho are full-time as of the October 14, 2013standard measurement period must haveaffordable minimum essential coverageoffered to them as of January 1, 2014 for theentire year, while employees who are not full-time do not have to be offered that coverageuntil they meet the full-time standards duringa standard measurement period. This givesthe employer a 2 ½-month administrativeperiod to add the employee to the plan.

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HOW CAN EMPLOYERS DETERMINE IF AN EMPLOYEE WORKS ANAVERAGE OF 30 HOURS PER WEEK? The guidance is short onspecificity and finality. That is still the case, but there is anadditional hint. The notice, in a footnote, states that earlierguidance indicated that the yet-to-be-issued regulations willpropose that an individual who works 130 hours in a calendarmonth will be treated as working an average of 30 hours perweek and will therefore be a full-time employee. This noticeseems to be more definitive regarding that standard. Whilethere is still no guidance upon which employers can rely, theuse of 130 hours per calendar month is at least an option foremployers to use for planning purposes. .

NEW EMPLOYEES

DETERMINATION MADE BY EMPLOYER BASED ONREASONABLE EXPECTATIONS

If an employee is reasonably expected at his or her start dateto work full-time, the employer would treat that employee as afull-time employee and offer coverage no later than the end ofthe 90-day waiting period (see below). Similarly, if anemployee is reasonably expected at his or her start date towork part-time (fewer than 30 hours a week), the employerwould treat that employee as a part-time employee, until andunless her hours of work changed. However, Notice 2012-58does not provide any exception based on the scheduled hoursof work, so all part-time employees excluded from coverageshould be tested using the hours counting rules.

VARIABLE-HOUR AND SEASONAL EMPLOYEES

Of course, whether new variable-hour and seasonal employeesqualify for eligibility will be more difficult to determine giventheir schedules. Therefore, selection of a standardmeasurement period is even more crucial given the variability.In such cases, an employer may use both a measurementperiod of three to 12 months and an administrative period ofup to 90 days (the same as allowed for ongoing employees).However, there is a slight difference here. The measurementperiod and the administrative period combined may notextend beyond the last day of the first calendar monthbeginning on or after the one-year anniversary of theemployee’s start date (totaling, at most, 13 months and afraction of a month).

VARIABLE-HOUR AND SEASONALEMPLOYEES DEFINED

An employee is a variable-hour employee if,based on the facts and circumstances on thedate the employee begins providing services tothe employer (the start date), it cannot bedetermined that the employee is reasonablyexpected to work an average of at least 30hours per week. (The 30 hours per week averageis the statutory definition of full-time employeein PPACA.)

A new employee who is expected to workinitially at least 30 hours per week may still be avariable-hour employee if, based on the factsand circumstances at the start date, the periodof employment at more than 30 hours per weekis reasonably expected to be of limited durationand the employer does not reasonably expectthe employee to work an average at least 30hours per week over the initial measurementperiod selected by the employer.

For example, a variable-hour employee wouldinclude a retail worker hired at more than 30hours per week for the holiday season. Thatemployee is reasonably expected to continueworking after the holiday season but is notreasonably expected to work at least 30 hoursper week for the portion of the initialmeasurement period remaining after the holidayseason, so that it cannot be determined at thestart date that the employee is reasonablyexpected to average at least 30 hours per weekduring the initial measurement period. So thatemployee would be a variable employee and themeasurement periods above regarding newvariable-hour employees would apply.

The notice confirms that there is no specificdefinition of seasonal employees in PPACA withrespect to determining full-time status.However, there are other definitions elsewherein Department of Labor regulations. Notice2012-58 permits employers to use a reasonable,good faith interpretation of the term “seasonalemployee;” but, as identified in the examples, toqualify for the safe harbor, an employer mustuse the same measurement and stability periodrules as apply to variable-hour employees.

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INITIAL MEASUREMENT PERIOD AND ASSOCIATED STABILITY PERIODFor variable-hour and seasonal employees, employers are permittedto determine whether the new employee is a full-time employeeusing an “initial measurement period” of between three and 12months (as selected by the employer).The employer measures thehours of service completed by the new employee during the initialmeasurement period and determines whether the employeecompleted an average of 30 hours of service per week or more duringthis period. Stability periods are determined in the same way asongoing employees.

IF A NEW VARIABLE-HOUR OR SEASONAL EMPLOYEE IS DETERMINED TO BE AFULL-TIME EMPLOYEE the employee is treated as a full-time employeefor a period of six consecutive calendar months or, if greater, thelength of the initial measurement period. The guidance states that“The stability period for such (new) employees must be the same asthe stability period for ongoing employees.” So, an employer thatwants to be sure they fall within the safe harbor will want to use thestability period for ongoing employees if it is longer than the initialmeasurement period.

IF A NEW VARIABLE-HOUR OR SEASONAL EMPLOYEE IS DETERMINED NOT TOBE A FULL-TIME EMPLOYEE the employer is permitted to treat theemployee as not a full-time employee for up to one month longerthan the initial measurement period but no longer than theremainder of the standard measurement period (plus any associatedadministrative period) in which the initial measurement period ends.In these circumstances, allowing a stability period to exceed theinitial measurement period by one month is intended to giveadditional flexibility to employers that wish to use a 12-monthstability period for new variable-hour and seasonal employees and anadministrative period that exceeds one month.

TRANSITION FROM NEW EMPLOYEE RULESTO ONGOING EMPLOYEE RULES

Once a new employee has been employed for an entire standardmeasurement period, the employee must be tested for full-timestatus at the same time and under the same conditions as otherongoing employees.

For example, an employer with a calendaryear standard measurement period that alsouses a 12-month initial measurement periodbeginning on the employee’s start date wouldtest a new variable-hour employee for full-time status, first based on the initialmeasurement period and again based on thecalendar year standard measurement period(if the employee continues in employment forthat entire standard measurement period)beginning on January 1 of the year after thestart date. So, a variable-hour employee witha February 12, 2014 start date would have aninitial measurement period of February 12,2014 through February 11, 2015, and astandard measurement period of January 1,2015 through December 31, 2015.

An employee determined to be a full-timeemployee during an initial measurementperiod or standard measurement period mustbe treated as a full-time employee for theentire associated stability period. This is thecase even if the employee is determined to bea full-time employee during the initialmeasurement period but determined not tobe a full-time employee during theoverlapping or immediately followingstandard measurement period. In that case,the employer may treat the employee as not afull-time employee only after the end of thestability period associated with the initialmeasurement period. Thereafter, theemployee’s full-time status would bedetermined in the same manner as that of theemployer’s other ongoing employees.

In contrast, if the employee is determined notto be a full-time employee during the initialmeasurement period, but is determined to be

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a full-time employee during the overlapping or immediately following standardmeasurement period, the employee must be treated as a full-time employee for the entirestability period that corresponds to that standard measurement period (even if that stabilityperiod begins before the end of the stability period associated with the initial measurementperiod). Thereafter, the employee’s full-time status would be determined in the samemanner as that of the employer’s other ongoing employees.

OPTIONAL ADMINISTRATIVE PERIOD FOR NEW EMPLOYEES

Employers may also add an administrative period to the initial measurement period beforethe start of the stability period. The administrative period may not exceed 90 days andincludes all periods between the start date of a new variable-hour or seasonal employee andthe date the employee is first offered coverage under the employer’s group health plan, otherthan the initial measurement period.

For example, if the employer begins the initial measurement period on the first day of thefirst month following a new variable-hour or seasonal employee’s start date, the periodbetween the employee’s start date and the first day of the next month must be taken intoaccount in applying the 90-day limit on the administrative period. Similarly, if there is aperiod between the end of the initial measurement period and the date the employee is firstoffered coverage under the plan, that period must be taken into account in applying the 90-day limit on the administrative period.

There is a limit on the combined length of the initial measurement period (of up to 12months) plus any administrative period (of up to 90 days) applicable for a new variable-houror seasonal employee. Combined, those periods cannot extend beyond the last day of thefirst calendar month beginning on or after the first anniversary of the employee’s start date.

For example, if an employer uses a 12-month initial measurement period for a new variable-hour employee, and begins that initial measurement period on the first day of the firstcalendar month following the employee’s start date, the period between the end of the initialmeasurement period and the offer of coverage to a new variable-hour employee who worksfull-time during the initial measurement period must not exceed one month. So, in thisexample, a variable-hour employee with a February 12, 2014 start date would have an initialmeasurement period of March 1, 2014 through February 28, 2015 and if determined to be afull-time employee, coverage must start no later than April 1, 2015.

EXAMPLES OF NEW VARIABLE-HOUR EMPLOYEES WITHAN ADMINISTRATIVE PERIOD

In these examples the new employee is a new variable-hour employee, and the employer haschosen to use a 12-month standard measurement period for new employees commencing onthe start date, and, a 12-month measurement period for ongoing employees starting October15. Both new and ongoing employees have a 12-month stability period:

� For new hires, coverage starts the first of the calendar month that is not more than 13months after hire

� For ongoing employees, coverage starts the subsequent January 1.

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Thus, for ongoing employees, during theadministrative period from October 15through December 31 of each calendar year,the employer continues to offer coverage toemployees who qualified for coverage for thatentire calendar year based upon working anaverage of at least 30 hours per week duringthe prior standard measurement period. Inthese examples, the employer offers healthplan coverage only to full-time employees(and their dependents).

EXAMPLE 1 – 12-MONTH INITIALMEASUREMENT PERIODFOLLOWED BY 1+ PARTIAL-MONTHADMINISTRATIVE PERIODAcme Industries hires Betty, Alice and Joanon May 10, 2014. Each works a variable-hourschedule. The initial measurement period isMay 10, 2014, through May 9, 2015.

Betty works an average of 30 hours per weekduring this initial measurement period. Acmeoffers coverage to Betty as a full-timeemployee during the stability period that runsfrom July 1, 2015 through June 30, 2016 (afterthe administrative period from May 9 throughJune 30).

Since Betty works an average of 30 hours perweek during her initial measurement periodthat did not exceed 12 months, and there wasan administrative period totaling not morethan 90 days; and the combined initialmeasurement period and administrativeperiod did not last beyond the final day of thefirst calendar month beginning on or after herone-year anniversary, Acme complied withthe pay or play mandate.

Acme must test Betty again based on theperiod from October 15, 2014 through October14, 2015 (Acme’s first standard measurementperiod that begins after Betty’s start date).

However, if the total Initial MeasurementPeriod plus the Administrative Periodsexceeds the first day of the month followingBetty’s anniversary, the plan would notcomply. So, in this case Acme hires her May10, 2014 and her initial measurement periodruns from June 1, 2014, through May 31, 2015.She works an average of 30 hours per weekduring this initial measurement period. If

Acme waits until August 1, 2015 to enroll her in coverage, Acmedoes not satisfy the standards for the safe harbor. To meet theterms of the safe harbor, the coverage would have to be offeredby July 1.

EXAMPLE 2 – CONTINUOUS FULL-TIME EMPLOYEESame as above but now Acme tests Betty as an ongoing employeebased on her hours from October 15, 2014 through October 14,2015 (Acme’s first standard measurement period that beginsafter her start date). Acme will pass the test if Betty works anaverage of 30 hours a week during that period and Acme offersher coverage July 1, 2016 through December 31, 2016. (Bettyalready has coverage for the period of January 1, 2016 throughJune 30, 2016, because that period is covered by the initialstability period following the initial measurement period, duringwhich she was already determined to be a full-time employee.)

EXAMPLE 3 – INITIALLY FULL-TIME EMPLOYEE,BECOMES NON-FULL-TIME EMPLOYEEAlice already has coverage through June 30, 2016 based on herinitial testing period. Acme again tests her as an ongoingemployee based on her hours from October 15, 2014 throughOctober 14, 2015 (Acme’s first standard measurement period thatbegins after Alice’s start date). If she works an average of 28hours a week during the period October 15, 2014 through October14, 2015, Acme must continue to offer coverage to Alice throughJune 30, 2016 (based on the initial testing period result) but isNOT required to offer her coverage for the period of July 1, 2016through December 31, 2016.

EXAMPLE 4 – INITIALLY NON-FULL-TIME EMPLOYEEJoan only works an average of 28 hours per week during the periodfrom May 10, 2014 through May 9, 2015 (her initial measurementperiod). Acme need not offer coverage to her for the remainder of2015. However, Acme must test Joan again as an ongoingemployee for the first standard measurement period followingher employment start date (October 15, 2014 through October 14,2015 in our example). If Joan works an average of 30 hours perweek during the October 15, 2014 to October 14, 2015 period,Acme must offer her coverage starting January 1, 2016 (the firststability period following the standard measurement period).

EXAMPLE OF SEASONAL EMPLOYEE

EXAMPLE 1 – 12-MONTH INITIAL MEASUREMENTPERIOD; 1+ PARTIAL MONTH ADMINISTRATIVE PERIODInfinity Industries runs a ski resort and offers health plancoverage only to full-time employees (and their dependents).Infinity hires Stan, a ski instructor, on November 15, 2014 andexpects him to work through March 15, 2015. Infinitydetermines that Stan is a seasonal employee based upon areasonable good faith interpretation of that term. His initialmeasurement period runs from November 15, 2014, through

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November 14, 2015 and he works 60 hours per week from November 15, 2014 through March 15, 2015. However, since heis not reasonably expected to average 30 hours per week for the 12-month measurement period, Infinity does not treatStan as a full-time employee and does not offer him coverage at hire. Coverage will start January 1, 2016 if Stan averages30 hours a week. So, the initial measurement period is not more than 12 months (and combined with the administrativeperiod does not extend beyond the first month beginning after his anniversary), thus Infinity complies with the safeharbor.

NINETY-DAY WAITING PERIOD

Group health plans may not require a waiting period that exceeds 90 days before coverage is effective for employees anddependents who are otherwise eligible for the plan. The plan can still have other eligibility requirements, such as beingin an eligible job classification or achieving job-related licensure requirements specified in the plan’s terms, unless thecondition is designed to avoid compliance with the 90-day waiting period limitation.

The requirement is based on eligibility, not the employee’s actual election, so the plan will still comply with therequirement even if employees take additional time to elect coverage.

If the plan requires full-time status for eligibility and it cannot be determined that a newly hired employee is reasonablyexpected to regularly work full-time, the plan may take a reasonable period of time to determine whether the employeemeets the plan’s eligibility condition. That period can be as long as the measurement period described above. Thewaiting period cannot exceed 90 days AFTER the measurement period. Therefore, employers can use the longest timeperiod described above for the determination of the employee’s full-time status and still meet the 90-day waiting periodlimitation if coverage is effective no later than 13 months from the employee’s start date, plus the time remaining (if any)until the first day of the next calendar month.

CONCLUSIONThe notices provide some much needed assistance to employers to begin planning for 2014. Employers may rely on therules in the notice through 2014. That means measurement periods will last through 2014 and could extend to stabilityperiods that last into 2016. The Notice offers an explicit safe harbor. The additional reliance a safe harbor provides islikely something that most employers will welcome.

Employers who restrict eligibility for coverage to full-time employees should review their existing processes andcapability for recording hours worked. We recommend such employers take immediate action to ensure such data arecaptured. As soon as practical thereafter, an employer may want to review the data to identify what measurementperiod and stability period best meets its needs in terms of managing coverage eligibility and minimizingadministrative costs.

More guidance is needed. The notice asks for comments from the public about the development of rules associated withthe short time assignments, temporary employees, high turnover positions or other special circumstances. The agenciesalso requested comments on other issues: mergers or acquisitions, variable start dates, more specific definitions ofseasonal employees, etc. Willis will update this Alert when more guidance is available.

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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, CT 203 924 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, MD 410 584 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 490 6808813 289 7996

Vero Beach, FL772 469 2842

MIDWEST

Appleton, WI800 236 3311

Chicago, IL312 288 7700312 348 7700

Cleveland, OH216 861 9100

Columbus, OH614 326 4722

Detroit, MI248 539 6600

Grand Rapids, MI616 957 2020

Milwaukee, WI414 203 5248414 259 8837

Minneapolis, MN763 302 7131 763 302 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

Novato, CA415 493 5210

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 ortax advice and has been prepared solely for educational purposes. Youmay wish to consult your attorney or tax adviser regarding issues raised in this publication.

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