I have a client who wants an opinion letter for its prototype Educational IRA document; however, I can not find where any LRMs have been issued nor where the IRS has said they will start accepting requests for opinion letters. Any news?

Just curious if anyone has heard anything recently - I realize that they are now Coverdale Savings Accounts, but still heard nothing re prototype language.

Anyone?

To the best of my knowledge, there is no IRS approval process existing or contemplated for Coverdell ESAs, which means no LRMs. If your client insists on receiving a favorable opinion letter, perhaps you can request one from a reputable law firm specializing in tax. While this is not a perfect substitute to a determination letter from the Service, at least it's something that says that your plan meets the requirements of Section 530.