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IRS Determination Letter Program to Be Curtailed
Towers Watson 
June 23, 2015 "The scaled-back program would shift the risk of a defective or missing provision to the plan sponsor -- and potentially to plan participants. This risk would accompany all provisions required or added after the IRS' initial determination letter. Such document-based claims might arise through an IRS audit or through a participant dispute about plan benefits. In an audit, the sponsor could face penalties as part of the correction process and might need to modify benefit amounts retroactively." |
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