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EGTRRA Restatement Issues


Guest igglesfan

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Guest igglesfan

I, like everyone else am still waiting for opinion letters for my EGTRRA Restatement. Let's assume they come out today. Would I still be able to put new clients onto my GUST Restatement until I have the system ready for EGTRRA, or do all new clients / amended plans have to get put onto the EGTRRA document?

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If the EGTRRA letter comes out today (assuming the letter does not indicate a later effective date that you cannot begin earlier than), then any new client you get now could go straight into that IRS-approved EGTRRA document (assuming you have an EGTRRA document ready for your use today).

If you don't have an EGTRRA document system ready yet, then they should be on a GUST document or an individually drafted document for now, until your EGTRRA document system is ready. Then, you will have to restate them to comply with EGTRRA. The IRS letter will probably tell you what your restatement deadline is. If they do not fit into the 6-year cycle, then you'll have to take a look at IRS Notice 2007-44 and Rev Proc 2005-66.

"do all new clients / amended plans have to get put onto the EGTRRA document?"

All qualified plans, yes. By the deadline the IRS prescribes.

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Guest igglesfan

Let me try to clarify. I can't find anything at all that says whether my GUST document is still valid after the issuance of my EGTRRA opinion letter.

Example:

EGTRRA Opinion Letter Comes out 4/1/2008. Can I, as of 4/20/2008 put a plan on a GUST document, so long as they restate for EGTRRA by 4/1/2010 (or whenever the close of the remedial amendment period is)?

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