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Allocating 'Basis' in Partial and Split Rollovers: Can We Still Rely on Code Section 402(c)(2)? (PDF)
Groom Law Group 
[Guidance Overview] Mar. 30, 2010 2 pages. Excerpt: Many plans and third party administrators (TPAs) thought 'yes' as well-settled law following EGTRRA, but the Service seems to disagree.... Therefore, we continue to recommend a 'wait and see' approach prior to making system/plan design changes. And we will continue to encourage the IRS and Treasury to reconsider their position and, in the event their position is firm, to issue prospective, binding authority that express addresses their position and makes it clear that prior transactions are not adversely affected. MORE >> |
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