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Kubler-Ross and IRS Announcement 2016-32
Benefits Bryan Cave Link to more items from this source
Sept. 23, 2016

"In Announcement 2016-32, the IRS requested comments on how [individually designed] plans can maintain compliance going forward since determination letters are no longer available.... The IRS is asking if there are additional provisions that would also be appropriate to incorporate by reference.... The IRS would like to know if there are other provisions that could possibly be avoided and the likelihood that the plan sponsor will actually amend the plan when the provision becomes applicable.... [T]here are challenges to switching to a pre-approved prototype or volume submitter plan, and the IRS wants to know about them ... What might depress practitioners most is that [these] are the only ones the IRS came up with as possibilities."

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