Guest ENT Posted December 28, 2011 Share 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? Link to comment Share on other sites More sharing options...
GBurns Posted December 28, 2011 Share 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) Link to comment Share on other sites More sharing options...
Guest ENT Posted December 28, 2011 Share 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 Link to comment Share on other sites More sharing options...
Guest ENT Posted December 28, 2011 Share 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. Link to comment Share on other sites More sharing options...
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