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Private Letter Rulings


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Can a private letter ruling be issued for a plan that has not yet been established? Section 6.02 of Rev. Proc. 2011-4 states that the EE Plans will issue letter rulings on proposed transactions and on completed transactions, which seems to suggest it can. However, section 8.03 states taht a letter ruling will not be issued on alternative plans of proposed transactions or on hypothetical situations.

Does anyone know if such a ruling request be considered to relate to a hypothetical situation merely because the plan has not been formally established?

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Are you sure that a private letter ruling is what you really need?

What is so different from established plan designs that suggests a need for such a ruling?

George D. Burns

Cost Reduction Strategies

Burns and Associates, Inc

www.costreductionstrategies.com(under construction)

www.employeebenefitsstrategies.com(under construction)

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Are you sure that a private letter ruling is what you really need?

What is so different from established plan designs that suggests a need for such a ruling?

Church plans are exempt from a number of qualification rules

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I believe a proposed plan pending IRS approval of its status would not be deemed "hypothetical," but also realize that Rev. Proc. 2011-44 requires notice to participants.

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