The new guidance relaxes some of the prior restrictions on the issuance of opinion and advisory letters for new pre-approved plans primarily in the case of plans that are identical to mass submitter plans.
Document Excerpt
This revenue procedure modifies Rev. Proc. 2007-44, 2007-28 I.R.B. 54 with respect to certain restrictions that apply to the issuance of opinion and advisory letters for new pre-approved plans. These restrictions were included in Rev. Proc. 2007-44 primarily to ensure that the use of Service resources to administer the pre-approved plan program does not adversely affect the determination letter program.
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