March 6, 1990
TO: PENSION MEMBERS NO. 11-90
RE: IRS REVENUE PROCEDURE REVISING USER FEE SCHEDULE
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Attached is a copy of Revenue Procedure 90-17, which
revises the schedule of user fees for rulings, opinion letters,
determination letters and similar requests established by the
Internal Revenue Service in Revenue Procedure 89-4. (See
Institute Memorandum to Pension Members No. 2-89, dated January
18, 1989).
The revised fees for opinion letters concerning master or
prototype plans generally are effective for applications filed
after September 30, 1990, but will apply only if Congress extends
the user fee program beyond September 30, 1990. If the program
is extended, the fee for a mass submission for an opinion letter
concerning a master or prototype plan would increase from $1,000
to $3,000 per basic plan document. A sponsoring organization
adopting a mass submitter's plan on a word-for-word basis would
pay a fee of $100 per adoption agreement, rather than the current
$50. The fee for a minor modification would remain at $400 per
adoption agreement. Nonmass submissions would require a fee of
$3,000 per adoption agreement, rather than the current $1,000.
We will keep you informed of further developments.
Kathy D. Ireland
Associate General Counsel
Attachment