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IRS Maintains Favorable Position on IRA Owner's Direct Payment of 'Wrap Fees'
Groom Law Group 
[Guidance Overview] Mar. 8, 2011
[The ruling] does not cover issues such as (1) whether payment of the fee from the IRA would be taxed as a distribution to the owner (presumably not), or (2) whether the owner can reimburse the IRA for the wrap fee and get the same favorable 'nonâ€contribution' outcome (presumably not, following a line of private letter rulings where the Service reversed itself after taking a favorable position). Nevertheless, the PLR is a helpful indicator of the Service's position on common current industry practices.
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