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New Rev. Proc. on EPCRS


david rigby

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I did nothing more than speed read the section in the beginning where it lists the changes, and it didn't appear to be much of a change. Largely just incorporating prior changes, modifications due to the determination letter program changing, some minor clarifications, moving stuff from one section to another, modifying the Appendix C Schedules, etc...

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same as Belgarath, simply looked at the changes, though I did look at

Appendix B, plan amendment to include ineligible, and the example still says submit for determination letter.

everywhere else they seem to say don't do this so I wonder if they simply missed on this item

of course, I guess anything is EPCRS including examples is 'definitely ok' and if you don't submit for a letter you are 'possibly taking your chances' but in light of the fact the IRS has practically begged you not to submit....

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