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| Piper Pension & Profit Sharing Comment Letter to IRS on Proposed Section 415 Regulations (PDF) Piper Pension & Profit Sharing  Aug. 25, 2005 16 pages. Excerpt: [T]here are fatal flaws in the proposed regulations which undermine the stated purpose of updating the regulations for accumulated changes due to changes in the law and resolution of ambiguities. Two proposed provisions reverse the positions taken by existing final regulations without a change in law and changes to historical Service positions regarding the effect of prior distributions violate both actuarial standards and the law. |
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