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IRS Provides Qualification Relief for Plans Affected by Anti-Cutback Decision
Deloitte 
Apr. 28, 2005
Excerpt: In Heinz, an amendment to a multiemployer pension plan expanded the types of post-retirement employment that would result in the suspension of benefit payments. The Court held that this amendment violated the prohibition against retroactive cutbacks in accrued benefits. The revenue procedure limits the retroactive impact of the Court's decision [for the purpose of qualification of a plan under Code section 401].
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