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Bloomberg Tax
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Detailed Analysis
I. Introduction
Introductory Material
A. Overview
1. Plan Selection
a. Defined Benefit Plans
b. Defined Contribution Plans
c. Permitted Disparity (Social Security Integration)
2. Plan Document
3. Plan Adoption
4. Plan Qualification
a. Benefits of Tax-Exempt Status
b. Advantages of Determination Letters
c. Employee Plans Compliance Resolution System Issues
d. Plan Termination
B. Scope and Purpose of Portfolio
II. Determination Letter Applications
A. Scope
B. What to File
1. Form 5300, Application for Determination for Employee Benefit Plan
2. Schedule Q, (Form 5300), Elective Determination Requests
3. Form 5307, Application for Determination for Adopters of Master or Prototype or Volume Submitter Plans
4. Form 5309, Application for Determination of Employee Stock Ownership Plan
5. Form 5310, Application for Determination for Terminating Plan
6. Supporting Documents
a. User Fees
b. Power of Attorney
c. Other Attachments
d. Cover Letter
7. Compiling the Package
C. Where to File
1. Determination Letter Applications
2. Related Procedures
a. IRS EP Technical
b. Tax Court Review
(1) Petitioner
(2) Notice
(3) Exhaustion of Administrative Remedies
(4) Plan in Effect
(5) Time for Action
D. When to File
1. General Remedial Amendment Period
a. Cyclical Remedial Amendment Periods
(1) In General
(2) General Remedial Amendment Period Extension
(3) Interim Amendments
(4) Pre-Approved Plans
b. EGTRRA Remedial Amendment Period
2. Extensions of the Remedial Amendment Period
3. Relief After the Remedial Amendment Period
E. Notice to Interested Parties
1. Who Are Interested Parties?
2. Type of Notice
III. Other Procedures for Obtaining Written Guidance
A. Other IRS Rulings and Written Guidance
1. Closing Agreements
2. Information Letters
3. Private Rulings
4. Rulings Areas
5. Rulings - Procedures
B. Department of Labor Rulings
1. Advisory Opinions
2. Information Letters
3. Prohibited Transaction Exemptions
C. Jurisdiction of Other Courts
D. Freedom of Information Act
Working Papers
Table of Worksheets
Worksheet 1 Cover Letter to Application for Determination Letter
Worksheet 2 Notice to Interested Parties of Plan's Application for a Determination Letter from the IRS
Worksheet 3 Selected IRS Alert Guidelines - Vesting and Minimum Participation
Worksheet 4 Selected IRS Alert Guidelines - Defined Benefit Plans: Coverage and Nondiscrimination; Permitted Disparity
Worksheet 5 Selected IRS Alert Guidelines - Distributions and Contributions
Worksheet 6 Plan Amendment Deadlines for Qualified Plans
Worksheet 7 Cumulative List of Changes in Pension Plan Qualification Requirements
Worksheet 8 Schedule of User Fees
Bibliography
OFFICIAL
Statutes:
Internal Revenue Code:
Treasury Rulings:
Cases:
UNOFFICIAL
Texts and Treatises:
Periodicals:
1983
1989
1992
1994
1997
2001
2002
2003
2006
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