WASHINGTON, D.C. | February 6, 2012
Dear Commissioner Shulman:
As you know the Internal Revenue Service (IRS) released an advance notice of proposed regulations titled "Determination of Government Plan Status." We understand these regulations would define the term "governmental plan" and will determine what a governmental plan is under section 414(d) of the Internal Revenue Code. It has been brought to our attention that these regulations, as currently drafted, would have negative consequences for teachers at public charter schools.
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