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Text of IRS PLR 201347028: Nature of Employer, Not Duties of Employees, Governs Exemptions from Section 415(b)(2) Reductions (PDF)
Internal Revenue Service [IRS] Link to more items from this source
[Official Guidance]
Nov. 22, 2013
"[Y]ou request a ruling that Agency A constitutes a police department organized and operated by State B to provide police protection and/or emergency medical services for State B for purposes of the exemption from the age-reduced 415(b) limit created by Code section 415(b)(2)(G) ... [I]dentifying qualified participants, for purposes of Code sections 415(b)(2)(G) and (H), requires an inquiry into the overall nature of the employer, and not the activities of any specific employees or groups of employees. In the present case, none of the operative laws, documents, or materials provided by Agency A describe an organization whose overall mission and nature is to be a police department."

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