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Affected Parties Suggest Reasons, Methods for Expanding IRS Determination Letter Program

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Retirement plan trade organizations and advocates, law firms, and other affected parties proposed to the Internal Revenue Service (IRS) an expanded range of circumstances they believe merit review and determination letter judgment by the tax agency.

But the recent responses to the IRS’ request for comments on its newly narrowed determination letter process (see related March 2017 story) may not persuade the agency to accept letter applications for significant design changes, mergers, multiemployer plans, or other circumstances that the stakeholders suggested, according to benefits consulting firm Conduent Inc.

What’s a Determination Letter?

In a determination letter, the IRS rules

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