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|IRS Announces Major Changes to Determination Letter Program|
McDermott Will & Emery
Aug. 4, 2015
"Cycle E and Cycle A plan sponsors should still submit timely determination letter requests for those plans.... Plan sponsors with individually designed plans should consider the Announcement and subsequent IRS guidance in deciding on a course of action. When determination letters are no longer effective, sponsors of individually designed plans may decide to seek expert opinions that plan terms comply with Section 401(a) of the Code."
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