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Disapproving the Approval Process: IRS Provides Additional Guidance on the Curtailment of the Determination Letter Program
Dechert LLP [Guidance Overview] Feb. 8, 2016
"[S]ponsors of Cycle A plans who are eligible to obtain an updated determination letter may wish to consider submitting an application for a letter on or before January 31, 2017.... It remains to be seen how much the combination of initial IRS approval, available IRS model language and IRS approval of plan terminations, together with a presumably expanded voluntary-compliance-system, will provide employers with sufficient practical comfort regarding plan establishment and administration."
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