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A Welcome Expansion: IRS Resuscitates Determination Letter Program
Ogletree Deakins Link to more items from this source
[Guidance Overview]
July 1, 2019

"The IRS has noted that partially statutory hybrid plans (e.g., plans that contain multiple benefit formulas, only one of which is a hybrid formula) are eligible for a determination letter--the plan need only have one hybrid formula to be eligible.... [Rev. Proc. 2019-20] also opens up the determination letter program to 'merged plans.' Although this term may seem to encompass many situations in which two plans are combined, plan sponsors should pay close attention to the requirements of the Revenue Procedure, including all applicable time limits[.]"

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