t.haley Posted January 15, 2009 Posted January 15, 2009 I have a client that was on a pre-approved VS plan effective 1 August 2003. Subsequently they changed administrators and went to another pre-approved VS plan effective 1 April 2005. Can they be a "prior adopter" since they had adopted a pre-approved plan prior to 17 February 2005? I don't think they can use the 6-year cycle by signing an 8905 because the requirements for an "intended adopter" require the employer to have a qualified individually designed plan. Any thoughts?
J Simmons Posted January 15, 2009 Posted January 15, 2009 Off the cuff, I think they are a prior adopter if there was not a gap of time after going off the old VS and onto the new one. John Simmons johnsimmonslaw@gmail.com Note to Readers: For you, I'm a stranger posting on a bulletin board. Posts here should not be given the same weight as personalized advice from a professional who knows or can learn all the facts of your situation.
t.haley Posted January 15, 2009 Author Posted January 15, 2009 Thanks for the replay. That's what I was thinking also. Of course I can't find anything "official" to substantiate it.
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