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June 24, 2022

IRS announces it won't rule on whether a transaction results in an employer reversion

In Revenue Procedure 2022-28, the IRS adds to its "no-rule list" (i.e. list of issues on which the agency will not issue private letter rulings or determination letters). Specifically, the IRS will not issue letter rulings  "on whether certain transactions result in an employer reversion within the meaning of [IRC Section] 4980(c)(2)."