PROPOSED AMENDMENTS TO NONDISCRIMINATION REQUIREMENTS AND OBSOLETE REVENUE RULINGS

January 28, 1993 TO: PENSION COMMITTEE NO. 4-93 RE: PROPOSED AMENDMENTS TO NONDISCRIMINATION REQUIREMENTS AND OBSOLETE REVENUE RULINGS __________________________________________________________ Attached is a copy of proposed amendments to the final nondiscrimination regulations under section 401(a)(4) of the Internal Revenue Code. The regulations were finalized in 1991, but the IRS subsequently published several notices describing proposed changes. (See Institute Memorandum to Pension Committee No. 23-92, dated July 2, 1992.) The proposed regulations incorporate a number of the changes described in the earlier notices, including the elimination of the uniform vesting and service crediting safe harbor requirements. Also attached is a copy of IRS Announcement 93-12, which lists the revenue rulings that the IRS proposes to declare obsolete in light of the 1986 Tax Reform Act changes to the nondiscrimination rules. We will keep you informed of developments. Kathy D. Ireland Associate Counsel - Pension Attachments