Loan & Distribution Specialist AimPoint Pension
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Defined Benefit Combo Cash Balance Compliance Consultant Loren D. Stark Company (LDSCO)
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AimPoint Pension
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Bates & Company, Inc.
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Regional Vice President of Sales The Retirement Plan Company
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Compass
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IRS Memorandum Limits Exceptions for Retaining Signed Retirement Plan Documents
Stinson [Guidance Overview] Dec. 27, 2019 "On December 13, 2019 the IRS released a Chief Counsel Memorandum ... addressing '[c]oncerns ... that taxpayers may argue that [Val Lanes v. Comm'r] supports the proposition that a taxpayer may attempt to meet the taxpayer's burden to have an executed plan document based on the production of an unsigned plan and a pattern and practice of signing documents given by an advisor.' ... Unfortunately, the Memorandum does not provide any guidance about the factors the IRS will consider in determining whether a taxpayer has met its burden that it executed a plan document." |
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