Loren D. Stark Company
Randall & Hurley, Inc.
EPIC Retirement Plan Services
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|GUST Extension Doesn't Address Anti-Cutback Problems; Amending by 2002 Year-End Might Be Prudent|
Nov. 21, 2002
Word on the street is that the IRS believes Rev. Proc. 2002-73 also extends the time for adopting good faith EGTRRA amendments to plans eligible for the extended GUST remedial amendment period under Rev. Proc. 2000-20, but because no section 411(d)(6) relief is provided for the EGTRRA amendments, top-heavy amendments would have to be adopted by the end of 2002 to avoid a prohibited cutback under a top-heavy plan if existing top-heavy provisions were not amended until after the 2002 year-end.
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