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IRS Issues Guidance on Determination Letter Program
Bradley Arant Boult Cummings LLP [Guidance Overview] July 6, 2016
"Although expiration dates on previously issued determination letters are no longer operative, sponsors may not rely on the letters with respect to any provisions that are subsequently amended or subsequently affected by any change in law. To assist in operational compliance, the IRS intends to provide an annual Operational Compliance List that will identify changes in qualification requirements that are effective during the calendar year."
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