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Recent Developments Affect Puerto Rico Retirement Plans (PDF)
Buck 
[Guidance Overview] Nov. 18, 2008
3 pages. Excerpt: Puerto Rico has enacted legislation that increases the pre-tax contribution limits to qualified savings plans under Section 1165(e) of the Puerto Rico Internal Revenue Code. Recent guidance provides that distributions from Puerto Rico profit sharing plans are not taxable in Puerto Rico upon company shutdowns. Also, the IRS issued a revenue ruling establishing that a transfer of assets from a U.S. qualified plan to a plan qualified only and exclusively under Section 1165 of the Puerto Rico Internal Revenue Code is a distribution to a participant whose account is included in the transfer, but the ruling is subject to important transition relief.
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