us-irs-private-letter-rulings-201511042•IRS written determination 201511042
IRS written determination 201511042
us-irs-private-letter-rulings-201511042IRS written determination 201511042Guidance
Private letter rulings and published taxpayer determination letters. Native document type is retained separately; a determination letter is not labeled a private letter ruling. These taxpayer-specific releases cannot be used or cited as precedent under 26 USC 6110(k)(3); applicability and current legal force are not independently certified. Keep repeated UILC subjects attached to one actual numbered document.
Significant Index No. 0412.06-00 TREASURY ERNAL REVENUE DE TAX EXEMPT AND GOVERNMENT ENTITIES DIVISION DEPARTMENT OF THE TREASURY INTERNAL REVENUE SERVICE WASHINGTON, D.C. 20224 201511042 DEC 18 2014 T: EP.RA: AZ Re: Company = Multiemployer Plan = Dear This letter is to inform you that the Company's requests for waivers of the minimum funding standard for the Plan for the plan years ending . and through' . 1, have been denied. In a letter dated : you were informed that your requests for waivers of the minimum funding standard had been tentatively denied and were offered a conference of right in accordance section 12.01 of Rev. Proc. 2014-4, 2014-1 I.R.B. 152. Our tentative denial was based on our analysis of the financial information provided by the Company. Our analysis concluded that the Company continues to experience a substantial business hardship that does not appear to be temporary, assuming the Company is required to continue funding the Plan as a single-employer plan. A key component of the Company's financial recovery plan, which was provided with the waiver requests, is the finalization of a merger of the Plan with the Multiemployer Plan. While the merger in itself would not necessarily resolve the Company's financial hardship, it would help it to stabilize its ongoing financial health. However, while the Company has been optimistic in the updates that it has given us since the conference of right took place the merger, which was expected to be finalized by has not taken place, and according to an update given to us on the trustees of the Multiemployer Plan have still not set a date to finalize the merger. Although we have asked for updated information concerning the merger in writing, we have not received the information from the Company to date. <!-- PageBreak --> <!-- PageHeader="201511042" --> Nevertheless, even if the merger takes place, our analysis concludes that the Company's financial hardship does not appear to be temporary. Many of the financial pressures that have caused the Company's former clients, most of which are multiemployer plans, to drop the Company's services have not been alleviated in the current economic climate. Our letter dated stated that if you did not contact us to schedule a conference within 21 days, we would finalize our ruling denying your request for waivers of the minimum funding standard for the Plan for the plan years ending and As of the date of this letter, we have not heard from you. Accordingly, your request for waivers of the minimum funding standard for the Plan for the plan years ending , and ' 1, has been denied. This ruling is directed only to the taxpayer that requested it. Section 6110(k)(3) of the Code provides that it may not be used or cited by others as precedent. We have sent a copy of this letter to the Manager, EP Classification in Baltimore, Maryland, and to the Manager, EP Compliance Unit in Chicago. If you require further assistance concerning this matter, please contact at Sincerely yours, Niee 1.Html5 William B. Hulteng, Manager Employee Plans Technical Cc: Manager, EP Classification Baltimore, Maryland Manager, EP Compliance Unit Chicago, Illinois
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