Guest merlin Posted October 15, 2002 Share Posted October 15, 2002 We're using the Corbel/Relius volume submitter plans for our GUST restaements.Corbel includes 94GAR adoption language in their EGTRRA amendment. The Corbel RAP expires 4/30/03, but in reading Rev. Rul. 2001-62 it looks like our db plans must adopt 94GAR by 12/31/02. This means that we either have to get our db GUST/EGTRRA amendments done by 12/31/02, or have our db plans adopt the appropriate 2001-62 model amendment by 12/31/02. Am I reading this correctly? Link to comment Share on other sites More sharing options...
Blinky the 3-eyed Fish Posted October 15, 2002 Share Posted October 15, 2002 Merlin, it depends when you are electing to use the 94 GAR Table. If you are electing to use it in 2002, then you need to amend the plan by the last day of the plan year in which you began to use it. If you elect to wait until it is required to be used (after December 31, 2002), you have until the end of that plan year to make the amendment. So for a calendar year plan where you are waiting until 2003 to use the 94 GAR Table, you have until 12/31/03 to amend your plan. "What's in the big salad?" "Big lettuce, big carrots, tomatoes like volleyballs." Link to comment Share on other sites More sharing options...
Guest merlin Posted October 16, 2002 Share Posted October 16, 2002 Thanks,Blinky. But what's troubling me is the effective date ON OR AFTER 12/31/02. I'm reading this to mean that I must use the 94GAR table for pye 12/31/02 and that means I have to amend by 12/31/02. I can use it earlier in 02 if I want,but no later. Am I being too stringent? Link to comment Share on other sites More sharing options...
david rigby Posted October 16, 2002 Share Posted October 16, 2002 http://www.taxlinks.com/rulings/2001/revrul2001-62.htm I believe that the table is required for "annuity starting dates on or after 12/31/02". The plan year is not relevant. It can be adopted with an earlier effective date. The adoption date is no later than the last day of the plan year which contains the effective date. I'm a retirement actuary. Nothing about my comments is intended or should be construed as investment, tax, legal or accounting advice. Occasionally, but not all the time, it might be reasonable to interpret my comments as actuarial or consulting advice. Link to comment Share on other sites More sharing options...
Blinky the 3-eyed Fish Posted October 16, 2002 Share Posted October 16, 2002 Merlin, I see what you are saying now and I agree that calendar year plans must be amended by 12/31/02. See this link as well on page 4. http://www.actuary.org/ear/pdf/spring_2002.pdf "What's in the big salad?" "Big lettuce, big carrots, tomatoes like volleyballs." Link to comment Share on other sites More sharing options...
Guest lisbetf Posted November 12, 2002 Share Posted November 12, 2002 What if your current document doesn't specify the table name, but instead says "the applicable mortality table as prescribed by/..."? Can't you wait until your GUST remedial amendment period is up to amend for this? Link to comment Share on other sites More sharing options...
Blinky the 3-eyed Fish Posted November 12, 2002 Share Posted November 12, 2002 Prescribed by what? I think that it is relevent how the remaining description reads. "What's in the big salad?" "Big lettuce, big carrots, tomatoes like volleyballs." Link to comment Share on other sites More sharing options...
AndyH Posted November 12, 2002 Share Posted November 12, 2002 I read something today that said this was going to be extended until Fall 2003 within the next few days. Link to comment Share on other sites More sharing options...
Guest slt Posted November 19, 2002 Share Posted November 19, 2002 Does anyone agree with me that Rev. Proc. 2002-73 DOES NOT extend the amendment date under 2001-62 for calendar year plans that are individual plans? Under Rev. Proc. 2002-73, the "later of" date is now tagged to the 2001-62 date and the GUST remedial amendment period. See section 4.01. Since the GUST remedial amendment period is long gone for calendar year individual plans, I see no helpful extension. :mad: Link to comment Share on other sites More sharing options...
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