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Showing content with the highest reputation on 09/19/2018 in all forums

  1. And then there will always be people like me.... http://www.addletters.com/bart-simpson-generator.htm#.W6DjhTbruJA
    2 points
  2. I agree with ERISAPPLE and would also recommend never restating, no matter how many amendments you have over how long a period, unless the IRS decides to issue DL's again to continuing plans, e.g. in a window after a major law change. The reason I recommend never restating is that, in any sort of review of your plan documents, whether an IRS audit, review by independent auditor, or due diligence review in an acquisition, you will be better off having, as a separate document, the last executed plan document that had a favorable DL, and then all your executed amendments, even if those become numerous. In that way, review will be limited to the amendments and it will also be very clear which document is the subject of the letter. For administration purposes, you can prepare an unexecuted "working copy" that is effectively a restated document, but I would recommend not adopting that "working copy" or executing it.
    1 point
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