Peter Gulia Posted January 13, 2022 Report Share Posted January 13, 2022 Does any vendor of IRS-preapproved plan documents offer a version that is similarly Hacienda-preapproved to meet Puerto Rico’s tax-qualification conditions? If any, is it available with IRC § 401(a)? with IRC § 403(b)? If not available as a dual-qualified document, does any vendor offer a document on which Hacienda issued a preapproval letter so a user may rely without submitting its own application? Peter Gulia PC Fiduciary Guidance Counsel Philadelphia, Pennsylvania 215-732-1552 Peter@FiduciaryGuidanceCounsel.com Link to comment Share on other sites More sharing options...
MDCPA Posted January 14, 2022 Report Share Posted January 14, 2022 I'm not aware the Hacienda has a preapproval process. It is my understanding that any plan intended to qualify under Puerto Rico Code must submit for it's own determination letter. Luke Bailey and Peter Gulia 2 Link to comment Share on other sites More sharing options...
Peter Gulia Posted January 15, 2022 Author Report Share Posted January 15, 2022 MDCPA, thank you for confirming what I feared. A practical result is that my pro bono client, a charity, cannot provide a retirement plan for a member charity's Puerto Rico employees. I am not admitted to practice before Puerto Rico’s Hacienda. Engaging a lawyer or certified public accountant who is admitted and competent to tax-qualify a retirement plan under Puerto Rico’s law is beyond either charity’s budget. Peter Gulia PC Fiduciary Guidance Counsel Philadelphia, Pennsylvania 215-732-1552 Peter@FiduciaryGuidanceCounsel.com Link to comment Share on other sites More sharing options...
CuseFan Posted January 18, 2022 Report Share Posted January 18, 2022 Peter, we have a PR RK practice and the leader of that practice tells me we have a pre-approved plan with Hacienda (but not dual qualified). I'll have him or someone from that group contact you. Thanks Kenneth M. Prell, CEBS, ERPA Vice President, BPAS Actuarial & Pension Services kprell@bpas.com Link to comment Share on other sites More sharing options...
CuseFan Posted January 18, 2022 Report Share Posted January 18, 2022 3 minutes ago, CuseFan said: we have a PR RK practice BPAS Peter Gulia 1 Kenneth M. Prell, CEBS, ERPA Vice President, BPAS Actuarial & Pension Services kprell@bpas.com Link to comment Share on other sites More sharing options...
MDCPA Posted January 18, 2022 Report Share Posted January 18, 2022 CuseFan - good to know. thanks! Link to comment Share on other sites More sharing options...
Peter Gulia Posted January 18, 2022 Author Report Share Posted January 18, 2022 CuseFan, thank you for the good news. And Bloomberg BNA's Tax Management Portfolio "International Pension Planning - Puerto Rico" (which I didn't have until today) confirms that Hacienda has a procedure for approving a prototype plan. Peter Gulia PC Fiduciary Guidance Counsel Philadelphia, Pennsylvania 215-732-1552 Peter@FiduciaryGuidanceCounsel.com Link to comment Share on other sites More sharing options...
CuseFan Posted January 19, 2022 Report Share Posted January 19, 2022 You're welcome. Kenneth M. Prell, CEBS, ERPA Vice President, BPAS Actuarial & Pension Services kprell@bpas.com Link to comment Share on other sites More sharing options...
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