Gregory
Aug 5 2004, 10:19 AM
With the repeal of 415(e), is it still necessary for an employer adopting a "prototype" SEP IRA, who once sponsored a now terminated DB plan covering the same employees, to file for a determination letter?
Thank you in adavance for any assistance!
Gary Lesser
Aug 5 2004, 11:12 AM
There shouldn't be a problem--415(e) no longer exist! However, there may be deduction issues under IRC 404(a)(7) depending upon when the DB plan was terminated and contributions made to ther plans.