The document provides guidance for employers on determining full-time employee status under the Affordable Care Act. It outlines safe harbors that allow employers to use look-back measurement periods to determine full-time status. For ongoing employees, employers can use a standard measurement period of 3-12 months followed by a stability period where coverage must be provided based on the measurement. For new variable hour or seasonal employees, an initial measurement period of 3-12 months can be used, followed by a stability period. The guidance aims to provide employers flexibility and certainty in their determinations of full-time status.

1. HUMAN CAPITAL PRACTICE
ALERT:
HEALTH CARE REFORM BILL
October 2012 www.willis.com
PPACA DETERMINATION OF FULL-
TIME EMPLOYEES – INTERIM SAFE
HARBOR
Employers have been anxiously awaiting guidance on how to determine full-time status for their
employees under the Patient Protection and Affordable Care Act (PPACA) – a determination
central to the “pay or play” and “affordability” mandates under PPACA and necessary for many
employers in their planning.
BACKGROUND
Beginning in 2014, PPACA requires employers with 50 or more full-time employees (or the
equivalent) to offer affordable health coverage that meets minimum requirements to all full-time
employees or be subject to potential penalties.
The IRS and Department of Labor issued long-awaited interim guidance on August 31, 2012 to
assist employers with their implementation. Notices 2012-58 and 2012-59 (also referred to by
the DOL as DOL Technical Release No. 2012-02) offer safe harbors (with new nomenclature
of course) for employer determinations of whether an employee is full-time for purposes of the
pay or play and affordability mandates under PPACA and the application of the 90 day maximum
waiting 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 rules
after 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 the
standard measurement periods (see below for more explanation) extend far enough into the
calendar year, the safe harbor may apply beyond the 2014 plan year. Employers that use the safe
harbor 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 rules
too 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 news
for 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 to
determine whether new variable-hour employees or seasonal employees are full-time
employees, without being subject to a penalty under §4980H of the Internal Revenue
Code (IRC).

2. PAY OR PLAY MANDATE IN THE IRC
Section 4980H of the Internal Revenue Code was added by PPACA and requires large
employers (those with the equivalent of 50 or more full-time employees) to offer
“affordable,” “minimum essential coverage” or pay a penalty. The penalty is often
referred to as the “pay or play” penalty, but the IRC refers to this as the “shared
responsibility” 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 one
employee obtains coverage via a state-based exchange, and the individual receives
tax credits for the purchase of that coverage, the employer is subject to an annual
penalty of $2,000 for all full-time employees (less the first 30). The penalty is
determined monthly and applies to all full-time employees, whether or not they have
coverage under the employer-sponsored plan.
If an employer offers “minimum essential coverage” to all full-time employees, but
the coverage is not “affordable,” the employer is subject to a penalty of $250 per
month for each full-time employee (annually $3,000) who was not offered
“affordable” coverage, obtains coverage via a state-based exchange and receives tax
credits for the purchase of that coverage. Affordability means that at least one
coverage option that meets the minimum essential benefits requirements has an
employee contribution for employee only coverage of no more than 9.5% of the
employee’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 asked
how they can be expected to know the employee’s household income to make an
affordability determination. In response, the IRS issued a safe harbor that permits an
employer to make a determination using the employee’s federal taxable wages in Box
1 of the W-2. While that adds some certainty in administration, it will likely understate
or overstate the actual household income, sometimes substantially.
ONGOING EMPLOYEES
EMPLOYERS SELECT THE STANDARD MEASUREMENT PERIOD
Ongoing employees are those that have been working for the employer for at least one
“standard measurement period.” Each employer may establish a standard measurement
period of three to 12 months to determine full-time status. The employer can use a calendar
year, or any other start and end dates for the standard measurement period, as long as the
determination is made on a uniform and consistent basis for all employees in the same
category (See: Permitted Employee Categories for Measurement Periods).
The determination is made on an individual basis. So, an employer who restricts eligibility
to full-time employees must count hours for all employees who may average less than 30
hours a week.
IF THE EMPLOYEE IS A FULL-TIME EMPLOYEE DURING THE STANDARD
MEASUREMENT PERIOD
Once the employer determines the standard measurement period, the employer will
determine 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. For
this purpose, the stability period must be at least six months but can be no shorter than the
standard measurement period that applied to that employee.
2 Willis North America • 10/12

3. IF THE EMPLOYEE IS NOT A FULL-TIME EMPLOYEE No guidance is provided about individuals
DURING THE STANDARD MEASUREMENT PERIOD who might move from one category to
If the employer determines that an employee has averaged fewer another; however, a conservative
than 30 hours per week during the standard measurement period and interpretation would apply the measurement
is therefore not a full-time employee, then the employer can treat period that has the more favorable result with
that employee as a part-time employee during the subsequent regard to eligibility for coverage.
“stability period” regardless of the number of hours worked during
the stability period. In this circumstance, the stability period can be ADMINISTRATIVE PERIOD
as long as the standard measurement period but no longer. In order to make a determination of the
employee’s status AND have time to
administer the plan properly based on that
status, the guidance provides up to a 90-day
PERMITTED EMPLOYEE CATEGORIES FOR administrative period safe harbor AFTER the
MEASUREMENT PERIODS standard measurement period. However, it
will have to overlap with the prior stability
The permissible categories of employee for this purpose are: period in order to prevent gaps in coverage
(assuming the individual was previously full-
1) Collectively bargained (i.e., union) employees and non- time during that stability period).
collectively bargained employees
2) Salaried and hourly employees THE FOLLOWING EXAMPLE IS PROVIDED BY THE
3) Employees of different entities (such as different subsidiaries) GUIDANCE: The Acme Co. has a 12-month
4) Employees located in different states
stability period from January 1 to December 31,
2014. Based on prior standard measurement
Other categories of employees might also qualify (such as
periods, the employees who are full-time have
employees in different divisions); however, the notice only identifies
these four categories as qualifying for the safe harbor. coverage during that period while part-time
employees do not. The standard measurement
Employers who want to minimize the number of full-time period runs from October 15, 2012 to the
employees will likely use separate categories. following October 14, 2013. That permits Acme
to have an administrative period between the
For many employers, a 12-month measurement period would result end of the standard measurement period and
in the fewest number of full-time employees as that would require the next stability period that follows. Both the
the most consistent status over a long period of time. However, it standard measurement period and the stability
would also result in a longer stability period for those employees period can each be 12 months. Employees
deemed full-time during the measurement period (meaning that
who are full-time as of the October 14, 2013
coverage would have to be offered even if they worked fewer hours
standard measurement period must have
during the stability period). For other employers, a shorter
affordable minimum essential coverage
measurement period may be the better option, since it will lead to
the shortest stability period for those employees deemed full-time. offered to them as of January 1, 2014 for the
Retail operations, or perhaps a ski resort, where activity is highly entire year, while employees who are not full-
seasonal, are examples of employers who might benefit from a time do not have to be offered that coverage
shorter measurement period. until they meet the full-time standards during
a standard measurement period. This gives
All employers who restrict eligibility to full-time employees should the employer a 2 ½-month administrative
start tracking hours and reviewing employment patterns in order to period to add the employee to the plan.
identify the measurement and stability periods that best meet their
needs and objectives.
3 Willis North America • 10/12

4. HOW CAN EMPLOYERS DETERMINE IF AN EMPLOYEE WORKS AN
AVERAGE OF 30 HOURS PER WEEK? The guidance is short on
VARIABLE-HOUR AND SEASONAL
specificity and finality. That is still the case, but there is an EMPLOYEES DEFINED
additional hint. The notice, in a footnote, states that earlier
guidance indicated that the yet-to-be-issued regulations will An employee is a variable-hour employee if,
propose that an individual who works 130 hours in a calendar based on the facts and circumstances on the
month will be treated as working an average of 30 hours per date the employee begins providing services to
the employer (the start date), it cannot be
week and will therefore be a full-time employee. This notice
determined that the employee is reasonably
seems to be more definitive regarding that standard. While
expected to work an average of at least 30
there is still no guidance upon which employers can rely, the hours per week. (The 30 hours per week average
use of 130 hours per calendar month is at least an option for is the statutory definition of full-time employee
employers to use for planning purposes. . in PPACA.)
NEW EMPLOYEES A new employee who is expected to work
initially at least 30 hours per week may still be a
variable-hour employee if, based on the facts
DETERMINATION MADE BY EMPLOYER BASED ON and circumstances at the start date, the period
REASONABLE EXPECTATIONS of employment at more than 30 hours per week
is reasonably expected to be of limited duration
If an employee is reasonably expected at his or her start date and the employer does not reasonably expect
to work full-time, the employer would treat that employee as a the employee to work an average at least 30
full-time employee and offer coverage no later than the end of hours per week over the initial measurement
the 90-day waiting period (see below). Similarly, if an period selected by the employer.
employee is reasonably expected at his or her start date to
For example, a variable-hour employee would
work part-time (fewer than 30 hours a week), the employer
include a retail worker hired at more than 30
would treat that employee as a part-time employee, until and
hours per week for the holiday season. That
unless her hours of work changed. However, Notice 2012-58 employee is reasonably expected to continue
does not provide any exception based on the scheduled hours working after the holiday season but is not
of work, so all part-time employees excluded from coverage reasonably expected to work at least 30 hours
should be tested using the hours counting rules. per week for the portion of the initial
measurement period remaining after the holiday
VARIABLE-HOUR AND SEASONAL EMPLOYEES season, so that it cannot be determined at the
start date that the employee is reasonably
Of course, whether new variable-hour and seasonal employees expected to average at least 30 hours per week
qualify for eligibility will be more difficult to determine given during the initial measurement period. So that
employee would be a variable employee and the
their schedules. Therefore, selection of a standard
measurement periods above regarding new
measurement period is even more crucial given the variability.
variable-hour employees would apply.
In such cases, an employer may use both a measurement
period of three to 12 months and an administrative period of The notice confirms that there is no specific
up to 90 days (the same as allowed for ongoing employees). definition of seasonal employees in PPACA with
However, there is a slight difference here. The measurement respect to determining full-time status.
period and the administrative period combined may not However, there are other definitions elsewhere
extend beyond the last day of the first calendar month in Department of Labor regulations. Notice
beginning on or after the one-year anniversary of the 2012-58 permits employers to use a reasonable,
employee’s start date (totaling, at most, 13 months and a good faith interpretation of the term “seasonal
fraction of a month). employee;” but, as identified in the examples, to
qualify for the safe harbor, an employer must
use the same measurement and stability period
rules as apply to variable-hour employees.
4 Willis North America • 10/12

5. INITIAL MEASUREMENT PERIOD AND ASSOCIATED STABILITY PERIOD For example, an employer with a calendar
For variable-hour and seasonal employees, employers are permitted year standard measurement period that also
to determine whether the new employee is a full-time employee uses a 12-month initial measurement period
using an “initial measurement period” of between three and 12 beginning on the employee’s start date would
months (as selected by the employer).The employer measures the test a new variable-hour employee for full-
hours of service completed by the new employee during the initial time status, first based on the initial
measurement period and determines whether the employee measurement period and again based on the
completed an average of 30 hours of service per week or more during calendar year standard measurement period
this period. Stability periods are determined in the same way as (if the employee continues in employment for
ongoing employees. that entire standard measurement period)
beginning on January 1 of the year after the
IF A NEW VARIABLE-HOUR OR SEASONAL EMPLOYEE IS DETERMINED TO BE A start date. So, a variable-hour employee with
FULL-TIME EMPLOYEE the employee is treated as a full-time employee a February 12, 2014 start date would have an
for a period of six consecutive calendar months or, if greater, the initial measurement period of February 12,
length of the initial measurement period. The guidance states that 2014 through February 11, 2015, and a
“The stability period for such (new) employees must be the same as standard measurement period of January 1,
the stability period for ongoing employees.” So, an employer that 2015 through December 31, 2015.
wants to be sure they fall within the safe harbor will want to use the
stability period for ongoing employees if it is longer than the initial An employee determined to be a full-time
measurement period. employee during an initial measurement
period or standard measurement period must
IF A NEW VARIABLE-HOUR OR SEASONAL EMPLOYEE IS DETERMINED NOT TO be treated as a full-time employee for the
BE A FULL-TIME EMPLOYEE the employer is permitted to treat the entire associated stability period. This is the
employee as not a full-time employee for up to one month longer case even if the employee is determined to be
than the initial measurement period but no longer than the a full-time employee during the initial
remainder of the standard measurement period (plus any associated measurement period but determined not to
administrative period) in which the initial measurement period ends. be a full-time employee during the
In these circumstances, allowing a stability period to exceed the overlapping or immediately following
initial measurement period by one month is intended to give standard measurement period. In that case,
additional flexibility to employers that wish to use a 12-month the employer may treat the employee as not a
stability period for new variable-hour and seasonal employees and an full-time employee only after the end of the
administrative period that exceeds one month. stability period associated with the initial
measurement period. Thereafter, the
TRANSITION FROM NEW EMPLOYEE RULES employee’s full-time status would be
determined in the same manner as that of the
TO ONGOING EMPLOYEE RULES employer’s other ongoing employees.
Once a new employee has been employed for an entire standard In contrast, if the employee is determined not
measurement period, the employee must be tested for full-time to be a full-time employee during the initial
status at the same time and under the same conditions as other measurement period, but is determined to be
ongoing employees.
5 Willis North America • 10/12

6. a full-time employee during the overlapping or immediately following standard
measurement period, the employee must be treated as a full-time employee for the entire
stability period that corresponds to that standard measurement period (even if that stability
period begins before the end of the stability period associated with the initial measurement
period). Thereafter, the employee’s full-time status would be determined in the same
manner 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 before
the start of the stability period. The administrative period may not exceed 90 days and
includes all periods between the start date of a new variable-hour or seasonal employee and
the date the employee is first offered coverage under the employer’s group health plan, other
than the initial measurement period.
For example, if the employer begins the initial measurement period on the first day of the
first month following a new variable-hour or seasonal employee’s start date, the period
between the employee’s start date and the first day of the next month must be taken into
account in applying the 90-day limit on the administrative period. Similarly, if there is a
period between the end of the initial measurement period and the date the employee is first
offered 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 12
months) plus any administrative period (of up to 90 days) applicable for a new variable-hour
or seasonal employee. Combined, those periods cannot extend beyond the last day of the
first 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 first
calendar month following the employee’s start date, the period between the end of the initial
measurement period and the offer of coverage to a new variable-hour employee who works
full-time during the initial measurement period must not exceed one month. So, in this
example, a variable-hour employee with a February 12, 2014 start date would have an initial
measurement period of March 1, 2014 through February 28, 2015 and if determined to be a
full-time employee, coverage must start no later than April 1, 2015.
EXAMPLES OF NEW VARIABLE-HOUR EMPLOYEES WITH
AN ADMINISTRATIVE PERIOD
In these examples the new employee is a new variable-hour employee, and the employer has
chosen to use a 12-month standard measurement period for new employees commencing on
the start date, and, a 12-month measurement period for ongoing employees starting October
15. 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 13
months after hire
For ongoing employees, coverage starts the subsequent January 1.
6 Willis North America • 10/12

7. Thus, for ongoing employees, during the Acme waits until August 1, 2015 to enroll her in coverage, Acme
administrative period from October 15 does not satisfy the standards for the safe harbor. To meet the
through December 31 of each calendar year, terms of the safe harbor, the coverage would have to be offered
the employer continues to offer coverage to by July 1.
employees who qualified for coverage for that
entire calendar year based upon working an EXAMPLE 2 – CONTINUOUS FULL-TIME EMPLOYEE
average of at least 30 hours per week during Same as above but now Acme tests Betty as an ongoing employee
the prior standard measurement period. In based on her hours from October 15, 2014 through October 14,
these examples, the employer offers health 2015 (Acme’s first standard measurement period that begins
plan coverage only to full-time employees after her start date). Acme will pass the test if Betty works an
(and their dependents). average of 30 hours a week during that period and Acme offers
her coverage July 1, 2016 through December 31, 2016. (Betty
EXAMPLE 1 – 12-MONTH INITIAL already has coverage for the period of January 1, 2016 through
MEASUREMENT PERIOD June 30, 2016, because that period is covered by the initial
FOLLOWED BY 1+ PARTIAL-MONTH stability period following the initial measurement period, during
ADMINISTRATIVE PERIOD which she was already determined to be a full-time employee.)
Acme Industries hires Betty, Alice and Joan
on May 10, 2014. Each works a variable-hour EXAMPLE 3 – INITIALLY FULL-TIME EMPLOYEE,
schedule. The initial measurement period is BECOMES NON-FULL-TIME EMPLOYEE
May 10, 2014, through May 9, 2015. Alice already has coverage through June 30, 2016 based on her
initial testing period. Acme again tests her as an ongoing
Betty works an average of 30 hours per week employee based on her hours from October 15, 2014 through
during this initial measurement period. Acme October 14, 2015 (Acme’s first standard measurement period that
offers coverage to Betty as a full-time begins after Alice’s start date). If she works an average of 28
employee during the stability period that runs hours a week during the period October 15, 2014 through October
from July 1, 2015 through June 30, 2016 (after 14, 2015, Acme must continue to offer coverage to Alice through
the administrative period from May 9 through June 30, 2016 (based on the initial testing period result) but is
June 30). NOT required to offer her coverage for the period of July 1, 2016
through December 31, 2016.
Since Betty works an average of 30 hours per
week during her initial measurement period EXAMPLE 4 – INITIALLY NON-FULL-TIME EMPLOYEE
that did not exceed 12 months, and there was Joan only works an average of 28 hours per week during the period
an administrative period totaling not more from May 10, 2014 through May 9, 2015 (her initial measurement
than 90 days; and the combined initial period). Acme need not offer coverage to her for the remainder of
measurement period and administrative 2015. However, Acme must test Joan again as an ongoing
period did not last beyond the final day of the employee for the first standard measurement period following
first calendar month beginning on or after her her employment start date (October 15, 2014 through October 14,
one-year anniversary, Acme complied with 2015 in our example). If Joan works an average of 30 hours per
the pay or play mandate. week during the October 15, 2014 to October 14, 2015 period,
Acme must offer her coverage starting January 1, 2016 (the first
Acme must test Betty again based on the stability period following the standard measurement period).
period from October 15, 2014 through October
14, 2015 (Acme’s first standard measurement
period that begins after Betty’s start date).
EXAMPLE OF SEASONAL EMPLOYEE
However, if the total Initial Measurement
EXAMPLE 1 – 12-MONTH INITIAL MEASUREMENT
Period plus the Administrative Periods PERIOD; 1+ PARTIAL MONTH ADMINISTRATIVE PERIOD
Infinity Industries runs a ski resort and offers health plan
exceeds the first day of the month following
coverage only to full-time employees (and their dependents).
Betty’s anniversary, the plan would not
Infinity hires Stan, a ski instructor, on November 15, 2014 and
comply. So, in this case Acme hires her May
10, 2014 and her initial measurement period expects him to work through March 15, 2015. Infinity
runs from June 1, 2014, through May 31, 2015. determines that Stan is a seasonal employee based upon a
She works an average of 30 hours per week reasonable good faith interpretation of that term. His initial
during this initial measurement period. If measurement period runs from November 15, 2014, through
7 Willis North America • 10/12

8. November 14, 2015 and he works 60 hours per week from November 15, 2014 through March 15, 2015. However, since he
is not reasonably expected to average 30 hours per week for the 12-month measurement period, Infinity does not treat
Stan as a full-time employee and does not offer him coverage at hire. Coverage will start January 1, 2016 if Stan averages
30 hours a week. So, the initial measurement period is not more than 12 months (and combined with the administrative
period does not extend beyond the first month beginning after his anniversary), thus Infinity complies with the safe
harbor.
NINETY-DAY WAITING PERIOD
Group health plans may not require a waiting period that exceeds 90 days before coverage is effective for employees and
dependents who are otherwise eligible for the plan. The plan can still have other eligibility requirements, such as being
in an eligible job classification or achieving job-related licensure requirements specified in the plan’s terms, unless the
condition 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 the
requirement 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 reasonably
expected to regularly work full-time, the plan may take a reasonable period of time to determine whether the employee
meets the plan’s eligibility condition. That period can be as long as the measurement period described above. The
waiting period cannot exceed 90 days AFTER the measurement period. Therefore, employers can use the longest time
period described above for the determination of the employee’s full-time status and still meet the 90-day waiting period
limitation 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.
CONCLUSION
The notices provide some much needed assistance to employers to begin planning for 2014. Employers may rely on the
rules in the notice through 2014. That means measurement periods will last through 2014 and could extend to stability
periods that last into 2016. The Notice offers an explicit safe harbor. The additional reliance a safe harbor provides is
likely something that most employers will welcome.
Employers who restrict eligibility for coverage to full-time employees should review their existing processes and
capability for recording hours worked. We recommend such employers take immediate action to ensure such data are
captured. As soon as practical thereafter, an employer may want to review the data to identify what measurement
period and stability period best meets its needs in terms of managing coverage eligibility and minimizing
administrative costs.
More guidance is needed. The notice asks for comments from the public about the development of rules associated with
the short time assignments, temporary employees, high turnover positions or other special circumstances. The agencies
also requested comments on other issues: mergers or acquisitions, variable start dates, more specific definitions of
seasonal employees, etc. Willis will update this Alert when more guidance is available.
8 Willis North America • 10/12

9. KEY CONTACTS
U.S. HUMAN CAPITAL PRACTICE OFFICE LOCATIONS
NEW ENGLAND ATLANTIC Mobile, AL Pittsburgh, PA Irvine, CA
251 544 0212 412 645 8506 949 885 1200
Auburn, ME Baltimore, MD
207 783 2211 410 584 7528 Orlando, FL Schaumburg, IL Las Vegas, NV
407 562 2493 847 517 3469 602 787 6235
Bangor, ME Knoxville, TN 602 787 6078
207 942 4671 865 588 8101 Raleigh, NC SOUTH
704 344 4856 CENTRAL Los Angeles, CA
Boston, MA Memphis, TN 213 607 6300
617 437 6900 901 248 3103 Savannah, GA Amarillo, TX
912 239 9047 806 376 4761 Novato, CA
Burlington, VT Metro DC 415 493 5210
802 264 9536 301 581 4262 Tallahassee, FL Austin, TX
850 385 3636 512 651 1660 Phoenix, AZ
Hartford, CT Nashville, TN 602 787 6235
860 756 7365 615 872 3716 Tampa, FL Dallas, TX 602 787 6078
813 490 6808 972 715 2194
Manchester, NH Norfolk, VA 813 289 7996 972 715 6272 Portland, OR
603 627 9583 757 628 2303 503 274 6224
Vero Beach, FL Denver, CO
Portland, ME Reston, VA 772 469 2842 303 765 1564 Rancho/Irvine, CA
207 553 2131 703 435 7078 303 773 1373 562 435 2259
MIDWEST
Shelton, CT Richmond, VA Houston, TX San Diego, CA
203 924 2994 804 527 2343 Appleton, WI 713 625 1017 858 678 2000
800 236 3311 713 625 1082 858 678 2132
NORTHEAST Rockville, MD
301 692 3025 Chicago, IL McAllen, TX San Francisco, CA
Buffalo, NY 312 288 7700 956 682 9423 415 291 1567
716 856 1100 SOUTHEAST 312 348 7700
Mills, WY San Jose, CA
Morristown, NJ Atlanta, GA Cleveland, OH 307 266 6568 408 436 7000
973 539 1923 404 224 5000 216 861 9100
New Orleans, LA Seattle, WA
Mt. Laurel, NJ Birmingham, AL Columbus, OH 504 581 6151 800 456 1415
856 914 4600 205 871 3300 614 326 4722
Oklahoma City, OK
New York, NY Charlotte, NC Detroit, MI 405 232 0651 The information contained
in this publication is not
212 915 8802 704 344 4856 248 539 6600
intended to represent legal or
Overland Park, KS tax advice and has been
Norwalk, CT Gainesville, FL Grand Rapids, MI 913 339 0800 prepared solely for
203 523 0501 352 378 2511 616 957 2020 educational purposes. You
San Antonio, TX may wish to consult your
attorney or tax adviser
Radnor, PA Greenville, SC Milwaukee, WI 210 979 7470
regarding issues raised in
610 254 7289 704 344 4856 414 203 5248 this publication.
414 259 8837 Wichita, KS
Wilmington, DE Jacksonville, FL 316 263 3211
302 397 0171 904 562 5552 Minneapolis, MN
763 302 7131 WESTERN
Marietta, GA 763 302 7209
770 425 6700 Fresno, CA
Moline, IL 559 256 6212
Miami, FL 309 764 9666
305 421 6208
9 Willis North America • 10/12