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New IRS Proposal on What Is a Government Agency and Government Retirement Plan

November 09, 2011

On November 7, 2011 the IRS issued an "advance notice of proposed rulemaking" on the definition of what is a government agency for retirement plans and on what is a government plan. The IRS has asked for public comment on the notice. This memo gives a first cut review of the notice. Because the rules are all based on facts and circumstances within prescribed criteria, retirement systems and public agencies should review their particular facts to fully understand the implications.

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Edward Bernard

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