Revenue Procedure 2008-52

[GBurns]

Does anyone know why this RR was even issued?

What prompted it ?

What is it trying to resolve ?

Any links to any discussions or articles on the subject would be greatly appreciated.

[QDROphile]

It wasn't necessary. The IRS did not issue the ruling. Trick question, or do you mean Notice 2008-62? It was necessary if only to get attention to the issue.

[GBurns]

It should have read Revenue Procedure 2008-52.

http://benefitslink.com/articles/guests/washbull080922.html

[QDROphile]

I can see why you would have a question of relevance if you thought it belonged on the 409A board. That is why I guessed at Notice 2008-62.

[GBurns]

I really could not think of another board.

I suspect that it might be related to a H&W/Cafeteria Plan issue but thought that most of those readers would not be aware of any implication, whereas 409 people might since it seems somewhat related to the payment of bonuses etc.

[Guest Eric.]

Take a look at the article found at the link below:

http://www.millerchevalier.com/files/Publi...2025%202008.pdf

It talks about Section 118 Accounting Method Changes, Rev. Proc. 2008-52 and has an interesting, though pretty light discussion on Shareholder capital, as well as a degree of audit & audit adjustment protection or, atleast, attempted mitigation thereof, as well as a few other related areas of interest.

It's not all of it, but it is a small piece to chew on.

[GBurns]

I initially saw that they were addressing alleged section 118 "abuses" and wondered about the extent of such "abuses". But they then quickly updated and expanded the coveraage as shown in the above Deloitte link which updated the previous Deloitte article from just a few weeks ago.

What are they really after ? None of the articles that I have seen so far has any reference to background, rationale, reason, purpose or anything.