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Posted

No, they are not the same. On plan termination you can't rely on the opinion letter. If you want reliance, you'd need to file for a determination letter using IRS Form 5310.

Posted

Since the plan never had its own determination letter, we probably wouldn't feel it necessary to file with the IRS. This assumes a small to medium size plan that had no significant problems.

Posted
...no significant problems.

Hmmm. That is one purpose of going to the IRS. Their definition of "significant" may be different from yours.

I'm a retirement actuary. Nothing about my comments is intended or should be construed as investment, tax, legal or accounting advice. Occasionally, but not all the time, it might be reasonable to interpret my comments as actuarial or consulting advice.

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