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No More Determination Letters? What's a Plan Sponsor to Do?
Osler, Hoskin & Harcourt LLPLink to more items from this source
July 23, 2015

"The IRS should consider the following changes to preserve individually-designed plans: Modify its rule that a document defect found on audit goes automatically into the closing agreement program ... Modify its long-criticized rule that interim and discretionary amendments must be adopted by the end of the year in which they are effective or the plan sponsor's tax return deadline for that year.... Approve major modifications to a plan, such as conversion to another type of plan as if a new plan had been adopted at the effective date of the change.... Issue more model and sample language and add choices, similar to the way that adoption agreements can be used for different choices."

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