Reliance Equivalent to Determination Letter. If an Employer can rely on a favorable opinion letter pursuant to this paragraph, the opinion letter shall be equivalent to a favorable determination letter. The favorable opinion letter shall be treated as a favorable determination letter for purposes of Section 21 of Revenue Procedure 2005-6, regarding the effect of a determination letter, and Section 5.01(4) of Revenue Procedure 2003-44, regarding the definition of “favorable letter” for purposes of the Employee Plans Compliance Resolution System (and as such Revenue Procedures are subsequently modified or superseded by written guidance issued by the Department of the Treasury or by the Internal Revenue Service); however, the extent of the Employer’s reliance may be limited, as provided above.
Appears in 7 contracts
Samples: Prototype Defined Contribution Plan (1st Constitution Bancorp), Prototype Defined Contribution Plan (Wellesley Bancorp, Inc.), Prototype Defined Contribution Plan (Savannah Bancorp Inc)
