The IRS released Employee Plans News – Summer 2010 Edition. It contains the following articles:
Thursday, June 24, 2010
Employee Plans News – Summer 2010 Edition
Thursday, May 20, 2010
Treasury Regulation [TD 9484] – Diversification Requirements for Certain Defined Contribution Plans
DEPARTMENT OF THE TREASURY TD 9484 contains final regulations under section 401(a)(35) of the Internal Revenue Code (Code) relating to diversification requirements for certain defined contribution plans holding publicly traded employer securities. These regulations will affect administrators of, employers maintaining, participants in, and beneficiaries of defined contribution plans that are invested in employer securities. IRC Section 401(a)(35) was added by the Pension Protection Act of 2006 (PPA) (Public Law 109–280—Aug. 17, 2006). The rules apply to plans holding "publicly traded employer securities" and will therefore not apply to most closely held ESOPs. In our Analysis of the IRC Section 401(a)(35) Proposed Regulations we discussed how the definition of "publicly traded" impacts many ESOP definitions which could create problems for thinly traded companies. IRS Notice 2009-97 – Extension of Deadline to Adopt Certain Retirement Plan Amendments provided an extended amendment deadline. Related Links:
Internal Revenue Service
26 CFR Part 1
RIN 1545-BH04 The final regulations are effective on May 19, 2010 and applicable for plan years beginning on or after January 1, 2011.Prior Guidance:
Transition guidance was provided in IRS Notice 2006-107, 2006-51 I.R.B. 1114 - Diversification Requirements for Qualified Defined Contribution Plans Holding Publicly Traded Employer Securities. The transition guidance was extended in IRS Notice 2008-7 - Extension of Transitional Relief for Diversification Requirements for Certain Defined Contribution Plans. Proposed Treasury Regulation - REG–136701–07 - Diversification Requirements for Certain Defined Contribution Plans is effective for plan years beginning on or after January 1, 2009. For 2008, plans may rely on IRS Notice 2006-107 or the proposed regulations.
Wednesday, May 19, 2010
Retirement News for Employers – Spring 2010 Edition
The IRS released Retirement News for Employers – Spring 2010 Edition. It contains the following articles:
- 401(k) Questionnaire Coming to 1,200 Employers
- Upcoming 5500 Filing Deadline
- Small Business Week
- We're Glad You Asked!
- Fixing Common Plan Mistakes: Improper Forfeiture Suspense Accounts
- IRS Employee Plans Videos - Helping Small Business Owners and Employees
- Save the Date for Our Nationwide Tax Forums!
- New Profit Sharing Publication
- The Filing Cabinet
- Desk Side Chat…With Monika Templeman - Who Can Represent a Plan Sponsor During an Employee Plans Examination?
- IRS Summer Phone Forums
- DOL News
- Employee Plans Published Guidance
- Mark Your Calendar
- Timing Is Everything Flyer.
Thursday, May 6, 2010
DOL Spring 2010 Semi-Annual Regulatory Agenda: QDIA Target Date Fund Disclosure
The DOL has released the DOL Spring 2010 Semi-Annual Regulatory Agenda. One of the topics is the QDIA Target Date Fund Disclosure : QDIA Target Date Fund Disclosure (EBSA) EBSA plans to enhance retirement security by proposing an amendment to its qualified default investment alternative (QDIA) regulation to ensure that comprehensive information about the benefits and risks of investing in target date funds is disclosed to participants in the required QDIA notice.
EBSA plans to enhance retirement security by proposing an amendment to its qualified default investment alternative (QDIA) regulation to ensure that comprehensive information about the benefits and risks of investing in target date funds is disclosed to participants in the required QDIA notice, ultimately supporting the Secretary's good jobs for everyone policy.
Key Action: Publication – Proposed Amendment to QDIA Regulation
The Department's EBSA plans to publish a proposed amendment to the QDIA regulation in August 2010. This guidance will ensure that plan participants are provided with comprehensive information to evaluate target date or similar funds that have been selected as their plan's default investment.
Key Concern and Issues to be addressed
The popularity of target date funds in 401(k)-type plans is growing, in part due to their inclusion as a category of permissible investments in the Department's QDIA regulation. According to a recent survey, almost 58 percent of 401(k)-type plans offered target date funds as an investment option in 2008. And out of the approximately 40% of 401(k)-type plans that contained an automatic enrollment feature, almost 60% of these plans used target date funds as a qualified default investment alternative.
Recent attention has focused on the importance of understanding the unique characteristics that distinguish target date funds from other types of investments, the differences among the various target date funds available, and how these differences can affect the retirement savings of employees. The Department anticipates that this proposed amendment will better assist plan participants in evaluating target date funds that have been selected as default investments. The Department intends that the information in the QDIA notice will be consistent with that which is disclosed to participants who actively make decisions among their plans' investment options.
Background
The Department published its final QDIA regulation in October 2007. Target date and similar funds were included in the regulation as one of the categories of investments that plan fiduciaries may use to invest on behalf of participants who do not give investment directions. One of the requirements that must be satisfied for a plan fiduciary to obtain relief under the QDIA regulation is a notice describing the plan's default investment must be furnished to participants.
In recent years, attention has been given to the adequacy of information that is disclosed, both to plan fiduciaries and to plan participants, about the benefits and risks of investing in target date funds. The Department's ERISA Advisory Council studied several aspects of target date funds in 2008, and in 2009 the Department and the U.S. Securities and Exchange Commission held a joint public hearing to examine several issues related to target date funds, including how they are selected by plan fiduciaries and by investors. Based on these studies and on testimony presented at the hearing, the Department decided to enhance and provide more specificity concerning the information about target date or similar funds that must be disclosed pursuant to the QDIA regulation.
You may also be interested in Field Assistance Bulletin No. 2008-03 – Guidance Regarding Qualified Default Investment Alternatives (29 CFR § 2550.404c-5) and the Qualified Default Investment Alternatives (QDIA) – DOL Final Regulations.
DOL Spring 2010 Semi-Annual Regulatory Agenda: Amendment to Claims Procedure Regulation
The DOL has released the DOL Spring 2010 Semi-Annual Regulatory Agenda. One of the topics is the Amendment to Claims Procedure Regulation: Amendment to Claims Procedure Regulation (EBSA) EBSA plans to update and clarify the claims procedure requirements to enhance retirement and health benefit security and to protect workers rights and benefits, ultimately supporting the Secretary's good jobs for everyone policy.
EBSA plans to update and clarify the claims procedure requirements to enhance retirement and health benefit security and to protect workers rights and benefits, ultimately supporting the Secretary's good jobs for everyone policy.
Key Action: Proposed Regulation
The Department's EBSA plans to publish a proposed regulation in April 2011 that will amend the current claims procedure regulation and enhance the claims review process.
Key Concern and Issues to be addressed
Due to the significance of the rules that govern the filing and review of 1.4 billion health, disability, and pension claims and 531,000 appeals annually, the Department will review the adequacy of the notice and timing and other requirements of the claims procedure regulation and propose changes necessary to ensure that workers receive timely, complete and understandable explanations of benefit claim denials, as well as a full and fair review of any denied claims when a claim determination is appealed to a plan fiduciary. This initiative also will update the claims procedure rules to comport with the requirements of the recently enacted Patient Protection and Affordable Care Act of 2010.
Background
Section 503(2) of the Employee Retirement Income Security Act requires that participants be provided a full and fair review of claims. The Department published the current claims procedure regulation on November 21, 2000. After almost 10 years of experience in implementing the current regulation, the Department believes there is a need to review the extent to which the claims procedure regulation is working, given its impact on the retirement and health benefit security and benefit determinations of so many Americans.
There are an estimated 2.8 million health plans covering 138 million participants and beneficiaries and 708,000 pension plans covering 124 million participants and beneficiaries subject to the current claims procedure regulation.
DOL Spring 2010 Semi-Annual Regulatory Agenda: Voluntary Fiduciary Correction Program (VFCP)
The DOL has released the DOL Spring 2010 Semi-Annual Regulatory Agenda. One of the topics is the Voluntary Fiduciary Correction Program (VFCP): Voluntary Fiduciary Correction Program (VFCP) (EBSA) The VFCP enhances retirement security and protects workers by encouraging compliance with the Employee Retirement Income Security Act (ERISA) and restoring plan assets and the payment of additional benefits.
In 2006, the Department of Labor published in the Federal Register an Update of the Voluntary Fiduciary Correction Program (VFCP), which simplified and expanded the original VFCP published in 2002. The VFCP enhances retirement security and protects workers by encouraging compliance with the Employee Retirement Income Security Act (ERISA) and restoring plan assets and the payment of additional benefits, ultimately supporting the Secretary's good jobs for everyone policy.
Key Concern and Issues to be addressed
The 2006 Update of the VFCP includes 19 categories of plan transactions that may be corrected under the Program and an online calculator for determining amounts to be restored to plans. The updated VFCP serves to both encourage and facilitate the use of the Program as a means by which to correct covered fiduciary violations.
Background
The VFCP is designed to encourage employers to voluntarily comply with ERISA by self-correcting certain violations of the law. Many workers can benefit from the VFCP as a result of the increased retirement security associated with restoration of plan assets and payment of additional benefits. It also helps plan officials understand the law. The 2006 Update of the VFCP describes how to apply the 19 categories of transactions covered, acceptable methods for correcting violations, and examples of potential violations and corrective actions. The Department issued the Update in response to public and internal comments on the preliminary revision of the VFCP published in April 2005. The 2006 Update of the VFCP was effective May 19, 2006. The Department also provides applicants conditional relief from payment of excise taxes for certain VFCP transactions under a class exemption related to the VFCP. The amended class exemption was also effective on May 19, 2006.
DOL Spring 2010 Semi-Annual Regulatory Agenda: Target Date Fund Selection Compliance Assistance Checklist
The DOL has released the DOL Spring 2010 Semi-Annual Regulatory Agenda. One of the topics is the Target Date Fund Selection Compliance Assistance Checklist: Checklists for Pension and Health (EBSA) EBSA plans to enhance retirement security by publishing compliance assistance guidance to plan sponsors regarding the evaluation and selection of target date funds as retirement plan investment options and investment choices for employees.
EBSA plans to enhance retirement security by publishing compliance assistance guidance to plan sponsors regarding the evaluation and selection of target date funds as retirement plan investment options and investment choices for employees, ultimately supporting the Secretary's good jobs for everyone policy.
Key Action: Publication – Fiduciary Checklist
The Department's EBSA plans to publish a compliance assistance checklist in Spring 2010. This guidance will assist plan sponsors in their evaluation and selection of target date funds as plan investment options and investment choices.
Key Concern and Issues to be addressed
The popularity of target date funds in 401(k)-type plans is growing. However, target date funds are not uniformly-designed investment products. Recent attention has focused on the importance of understanding the unique characteristics that distinguish target date funds from other types of investments, the differences among the various target date funds available, and how these differences can affect the retirement savings of employees. The Department anticipates that its guidance will assist plan fiduciaries in evaluating and selecting from the different target date funds that are available.
Background
Under the Employee Retirement Income Security Act (ERISA), plan fiduciaries responsible for selecting plan investment options must act prudently and solely in the interest of the plan's participants and beneficiaries. In 2008, the Department's ERISA Advisory Council studied several aspects of target date funds, include challenges faced by plan fiduciaries in selecting and monitoring appropriate target date funds for their plans, and recommended that the Department provide additional guidance to plan fiduciaries. In 2009, the Department and the U.S. Securities and Exchange Commission held a joint public hearing to examine several issues related to target date funds, including how they are selected by plan fiduciaries and by investors. Several witnesses at the hearing also indicated that plan fiduciaries would benefit from additional guidance on the evaluation and selection of target date funds.
Surveys and studies suggest that target date funds are growing in popularity in 401(k)-type plans, both as investment options generally and as qualified default investment alternatives for participants who do not provide investment direction. For example, according to a recent survey, almost 58 percent of 401(k)-type plans offered target date funds as an investment option in 2008. Also, out of the approximately 40% of 401(k)-type plans that contained an automatic enrollment feature, almost 60% of these plans used target date funds as a qualified default investment alternative. With the growing popularity of target date funds as plan investment options and choices, the Department believes that providing additional guidance to plan fiduciaries will help enhance retirement security for employees.
DOL Spring 2010 Semi-Annual Regulatory Agenda: Delinquent Filer Voluntary Compliance Program (DFVCP)
The DOL has released the DOL Spring 2010 Semi-Annual Regulatory Agenda. One of the topics is the Delinquent Filer Voluntary Compliance Program: Delinquent Filer Voluntary Compliance Program (DFVCP) (EBSA) The Delinquent Filer Voluntary Compliance Program (DFVCP) is designed to encourage voluntary compliance with the annual reporting requirements under the Employee Retirement Income Security Act (ERISA).
The Delinquent Filer Voluntary Compliance Program (DFVCP) is designed to encourage voluntary compliance with the annual reporting requirements under the Employee Retirement Income Security Act (ERISA). The DFVCP gives delinquent plan administrators a way to avoid potentially higher civil penalty assessments by voluntarily correcting the failure to file an annual report on time, satisfying the program's requirements and voluntarily paying a reduced penalty amount.
Key Concern and Issues Addressed
Eligibility for the DFVCP is limited to plan administrators with filing obligations under Title I of ERISA who comply with the provisions of the program and who have not been notified in writing by the Department of a failure to file a timely annual report under Title I of ERISA. Participation in the DFVCP is a two-part process. First, file a complete Form 5500 Series Annual Return/Report, including all required schedules and attachments, for each year relief is requested. Special simplified rules apply to "top hat" plans and apprenticeship and training plans. Second, submit to the DFVCP a copy of the 5500, without the schedules and attachments, and the applicable penalty amount. The plan administrator is personally liable for the applicable penalty amount, and, therefore, amounts paid under the DFVCP shall not be paid from the assets of an employee benefit plan. An online calculator is available to assist filers in computing the penalty. Additionally, after completing the calculator, located at www.efast.dol.gov, filers may choose to pay the penalty electronically.
Background
The procedures governing participation in the program are intended to make the program easy to use. The program description is being updated to conform to guidance on filing delinquent 5500s under the Department's new EFAST2 wholly electronic filing system. Questions about the DFVCP should be directed to EBSA by calling 202.693.8360 or www.dol.gov/ebsa. For additional information about the Form 5500 Series, visit the EFAST Internet site at www.efast.dol.gov, or call the EBSA help desk at 1.866.463.3278.
We have previously discussed the DFVCP in Behind in your IRS Forms 5500 filings? and in DFVCP Penalty Calculator and Online Payment.
Monday, April 12, 2010
IRS Announcement 2010-20 – Issuance of Opinion and Advisory Letters and Opening of the EGTRRA Determination Letter Program for Pre-Approved Defined Benefit Plans
Part IV. Items of General Interest IRS Announcement 2010-20 – Issuance of Opinion and Advisory Letters and Opening of the EGTRRA Determination Letter Program for Pre-Approved Defined Benefit Plans This document announces that the Service will soon issue opinion and advisory letters for pre-approved (i.e., master and prototype (M&P) and volume submitter (VS)) defined benefit plans that were restated for the Economic Growth and Tax Relief Reconciliation Act of 2001 ("EGTRRA") and other changes in plan qualification requirements listed in Notice 2007-3 ("the 2006 Cumulative List") and that were filed with the Service. The Service expects to issue the letters on March 31, 2010, or, in some cases, as soon as possible thereafter. A plan that receives a favorable letter with respect to its restatement for EGTRRA and the 2006 Cumulative List is referred to as an "EGTRRA-approved plan." Employers using these pre-approved plan documents to restate a plan for EGTRRA and the 2006 Cumulative List will be required to adopt the EGTRRA-approved plan document by April 30, 2012. The Service will accept applications for individual determination letters submitted by adopters of these pre-approved plans starting on May 1, 2010. Related Links:
Monday, March 22, 2010
Employee Plans News – Spring 2010 Edition
The IRS released Employee Plans News – Spring 2010 Edition. It contains the following articles:
March 31, 2010
Monday, March 15, 2010
Treasury Regulation [REG–148681-09] – Notice of Proposed Rulemaking Request for Information Regarding Lifetime Income Options for Participants and Beneficiaries in Retirement Plans
DEPARTMENT OF THE TREASURY
Internal Revenue Service
26 CFR Part 1
RIN 1545-BJ04
DEPARTMENT OF LABOR
Employee Benefits Security Administration
29 CFR Parts 2509, 2520 and 2550
RIN 1210-AB33
Treasury Regulation [REG–148681-09] – Notice of Proposed Rulemaking Request for Information Regarding Lifetime Income Options for Participants and Beneficiaries in Retirement Plans
The Department of Labor and the Department of the Treasury (the “Agencies”) are currently reviewing the rules under the Employer Retirement Income Security Act (ERISA) and the plan qualification rules under the Internal Revenue Code (Code) to determine whether, and, if so, how, the Agencies could or should enhance, by regulation or otherwise, the retirement security of participants in employer-sponsored retirement plans and in individual retirement arrangements (IRAs) by facilitating access to, and use of, lifetime income or other arrangements designed to provide a lifetime stream of income after retirement. The purpose of this notice is to solicit views, suggestions and comments from plan participants, employers and other plan sponsors, plan service providers, and members of the financial community, as well as the general public, on this important issue...Comments must be submitted on or before May 3, 2010.
Here is the DOL news release seeking public comments on lifetime income options:
Washington – The U.S. Departments of Labor and the Treasury today announced the publication of a request for information (RFI) soliciting public comments to assist the agencies in determining what steps to take to enhance retirement security for workers in employer-sponsored retirement plans through lifetime annuities or other arrangements that provide a stream of income after retiring. The RFI appears in today’s edition of the Federal Register.
“Today’s initiative is particularly important given the shift from defined benefit plans that offer employees lifetime annuities to 401(k) and other defined contribution plans that typically distribute retirement savings in a lump sum payment,” said Phyllis C. Borzi, assistant secretary for the Labor Department’s Employee Benefits Security Administration.
The RFI seeks comments on a broad range of topics, including:
- The advantages and disadvantages of distributing benefits as a lifetime stream of income both for workers and employers, and why lump sum distributions are chosen more often than a lifetime income option.
- The type of information participants need to make informed decisions in selecting the form of retirement income.
- Disclosure of participants’ retirement income in the form of account balances as well as in the form of lifetime streams of payment.
- Developments in the marketplace that relate to annuities and other lifetime income options.
Related Links:
- Treasury Regulation [REG–148681-09] – Notice of Proposed Rulemaking Request for Information Regarding Lifetime Income Options for Participants and Beneficiaries in Retirement Plan [HTML]
Federal Register - 2010-11 I.R.B. (March 15, 2010)
- DOL News Release
- DOL Request for Information Regarding Lifetime Income Options for Participants and Beneficiaries in Retirement Plans
Friday, February 26, 2010
U.S. Labor Department rules to improve retirement security announced as part of White House Middle Class Task Force's year-end report
The DOL announced two new rules. One rule is designed to help workers obtain unbiased advice about how to invest in their IRAs and 401(k) plans and the other establishes new guidelines on disclosures for multiemployer retirement plans:
Washington – Today, at a White House forum hosted by Vice President Joe Biden, the U.S. Department of Labor announced two new rules designed to enhance retirement security and transparency for the millions of workers covered by 401(k), pension and other retirement arrangements. The announcement was part of the White House Middle Class Task Force's year-end report, which the vice president released at this morning's event.
During the past year, the Middle Class Task Force has focused on solutions to the challenges facing America's middle class - including retirement security and the need for high-quality jobs for middle class workers. The report details the year's work of the task force, and it includes a proposed rule on investment advice. The department also is announcing the publication of a final rule on multiemployer plan transparency.
"A secure retirement is essential to workers and the nation's economy. Along with Social Security and personal savings, secure retirement allows Americans to remain in the middle class when their working days are done. And, the money in the retirement system brings tremendous pools of investment capital, creating jobs and expanding our economy," said U.S. Deputy Secretary of Labor Seth Harris. "These rules will strengthen America's private retirement system by ensuring workers get good, objective information. When that happens, workers make the kind of decisions that are good for their families and the nation as the whole."
The first of the two rules would ensure workers receive unbiased advice about how to invest in their individual retirement accounts or 401(k) plans. If the rule is adopted, it would put in place safeguards preventing investment advisors from slanting their advice for their own financial benefit. Investment advisors also would be required to disclose their fees, and computer models used to offer advice would have to be certified as objective and unbiased. The department estimates that 2 million workers and 13 million IRA holders would benefit from this rule to the tune of $6 billion.
The second rule announced today establishes new guidelines on the disclosure of funding and other financial information to workers participating in multiemployer retirement plans - those collectively bargained by unions and groups of employers. It will ensure transparency by guaranteeing workers can better monitor the financial condition and day-to-day operations of their retirement investments. The rule will go into effect in April 2010.
Related Links:
Monday, February 22, 2010
Retirement News for Employers – Winter 2010 Edition
The IRS released Retirement News for Employers – Winter 2010 Edition. It contains the following articles:
Tuesday, February 2, 2010
IRS Notice 2010-15 – Miscellaneous HEART Act Changes
Part III --- Administrative, Miscellaneous, and Procedural IRS Notice 2010-15 – Miscellaneous HEART Act Changes Notice 2010-15 provides guidance in the form of questions and answers with respect to certain provisions of the Heroes Earnings Assistance and Relief Tax Act of 2008 ("HEART Act"). The notice also requests comments regarding any additional issues relating to the sections of the HEART Act that are addressed in the notice. Related Links: Related Blog Posts:
IRS Announcement 2010-03 – Automatic Approval of Changes in Funding Method for Takeover Plans and Changes in Pension Valuation Software
Part IV. Items of General Interest IRS Announcement 2010-03 – Automatic Approval of Changes in Funding Method for Takeover Plans and Changes in Pension Valuation Software Automatic approval of changes in funding method for takeover plans and changes in pension valuation software. This announcement provides, for plan years beginning on or after January 1, 2009, automatic approval for certain changes in funding method with respect to single-employer defined benefit plans that result either from a change in the valuation software used to determine the liabilities for such plans or from a change in the enrolled actuary and the business organization providing actuarial services to the plan. This guidance is being provided in response to numerous requests from actuaries and plan sponsors, many of whom are continuing to modify their valuation software in order to implement the changes to the funding rules made by the Pension Protection Act of 2006, the Worker, Retiree, and Employer Recovery Act of 2008, and guidance regarding these legislative changes. Related Links:
IRS Notice 2010-06 - Relief and Guidance on Corrections of Certain Failures of a Nonqualified Deferred Compensation Plan to Comply with § 409A(a)
Part III --- Administrative, Miscellaneous, and Procedural IRS Notice 2010-06 – Relief and Guidance on Corrections of Certain Failures of a Nonqualified Deferred Compensation Plan to Comply with § 409A(a) This notice provides rules governing the taxation of nonqualified deferred compensation plans. Section 409A of the Code requires that a nonqualified deferred compensation plan meet certain plan document requirements, and that the plan be operated in compliance with the plan document. Notice 2010-6 permits taxpayers to correct certain failures of a nonqualified deferred compensation plan to comply with the plan document requirements of section 409A, or in certain circumstances, to limit the amount includible in income and additional taxes under section 409A as a result of a plan document failure. Notices 2008-113 and 2008-115 modified. Related Links:
Wednesday, January 20, 2010
IRS Revenue Procedure 2010-08 - Rulings and determination letters
26 CFR 601.201: Rulings and determination letters. IRS Revenue Procedure 2010-08 - Rulings and determination letters User fees for employee plans and exempt organizations. Up-to-date guidance for complying with the user fee program of the Service as it pertains to requests for letter rulings, determination letters, etc., on matters under the jurisdiction of the Office of the Division Commissioner, Tax Exempt and Government Entities Division, is provided. Rev. Proc. 2009-8 superseded. Related Links:
IRS Revenue Procedure 2010-06 - Rulings and determination letters
26 CFR 601.201: Rulings and determination letters. IRS Revenue Procedure 2010-06 - Rulings and determination letters Employee plans determination letters. Revised procedures are provided for issuing determination letters on the qualified status of employee plans under sections 401(a), 403(a), 409, and 4975 of the Code. Rev. Proc. 2009-6 superseded. Related Links:
IRS Revenue Procedure 2010-05 - Rulings and determination letters
26 CFR 601.201: Rulings and determination letters. IRS Revenue Procedure 2010-05 - Rulings and determination letters Technical advice. Revised procedures are provided for furnishing technical advice to area managers and appeals offices by the Office of the Division Commissioner, Tax Exempt and Government Entities, regarding issues in the employee plans area (including actuarial matters) and in the exempt organizations area. Rev. Proc. 2009-5 superseded. Related Links:
IRS Revenue Procedure 2010-04 - Rulings and determination letters
26 CFR 601.201: Rulings and determination letters. IRS Revenue Procedure 2010-04 - Rulings and determination letters Rulings and information letters; issuance procedures. Revised procedures are provided for furnishing ruling letters, information letters, etc., on matters related to sections of the Code currently under the jurisdiction of the Office of the Division Commissioner, Tax Exempt and Government Entities. Rev. Proc. 2009-4 superseded. Related Links:
