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  1. Peter Gulia
    An employer has an EIN ending in 6. Its ESOP has a determination letter dated April 2014. So far, no one offers a useful prototype or volume-submitter document to restate the plan on. If concerning an individually-designed plan an Internal Revenue Code change makes a tax-qualification amendment necessary (and Congress's Act doesn't provide a special remedial-amendment period), when must the plan's sponsor complete the amendment? According to the regulations' ordinary remedial-amendment period without an extension or other administrative grace?
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