Guest ENT Posted December 28, 2011 Posted December 28, 2011 Can a private letter ruling be issued for a plan that has not yet been established? Section 6.02 of Rev. Proc. 2011-4 states that the EE Plans will issue letter rulings on proposed transactions and on completed transactions, which seems to suggest it can. However, section 8.03 states taht a letter ruling will not be issued on alternative plans of proposed transactions or on hypothetical situations. Does anyone know if such a ruling request be considered to relate to a hypothetical situation merely because the plan has not been formally established?
GBurns Posted December 28, 2011 Posted December 28, 2011 Are you sure that a private letter ruling is what you really need? What is so different from established plan designs that suggests a need for such a ruling? George D. Burns Cost Reduction Strategies Burns and Associates, Inc www.costreductionstrategies.com(under construction) www.employeebenefitsstrategies.com(under construction)
Guest ENT Posted December 28, 2011 Posted December 28, 2011 Are you sure that a private letter ruling is what you really need?What is so different from established plan designs that suggests a need for such a ruling? Church plans are exempt from a number of qualification rules
Guest ENT Posted December 28, 2011 Posted December 28, 2011 I believe a proposed plan pending IRS approval of its status would not be deemed "hypothetical," but also realize that Rev. Proc. 2011-44 requires notice to participants.
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