December 5, 1991
TO: PENSION COMMITTEE NO. 37-91
RE: IRS CORRECTION OF NOTICE 91-38
__________________________________________________________
Last month, the IRS issued Notice 91-38, which provides for
certain transitional rules for the recently finalized
nondiscrimination regulations. (See Institute Memorandum to
Pension Committee No. 36-91, dated November 21, 1991.) Attached
is a copy of an IRS memorandum correcting the second and third
paragraphs in II.A. of Notice 91-38. The correction clarifies
that employers who need transitional relief only for the 1992
plan year may operate under Alternative II D of Notice 88-131 for
the first time in the 1992 plan year.
We will keep you informed of developments.
Kathy D. Ireland
Associate Counsel - Pension
Attachment