An IRS announcement said the 2007 restrictions effectively limited the ability of sponsors of pre-approved plans (such as banks, insurance companies, and law firms) to apply for opinion and advisory letters for new plans after March 31, 2008, and also limited the ability of adopting employers to rely on letters issued for new plans.
Explaining that the restrictions were intended to make sure the expenditure of resources for the pre-approved program did not hurt the ability of the IRS to carry out its determination letter policies, the agency wrote in Rev. Proc. 2008-56: “After further evaluation and consideration of comments from pre-approved plan sponsors, the Service is relaxing these restrictions.”
In general, the changes in this revenue procedure apply only to plans that are identical to mass submitter plans.
The IRS explained: “Since the plans affected by the changes have, in effect, already been reviewed and approved, the service is able to make the changes without reducing resources needed for the determination letter program.”
The new revenue procedure is available here .
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