A written statement issued by the IRS to a plan sponsor as to the acceptability (for purposes of qualified plans)
- of the form of a master or prototype plan and any related trust or custodial account under a qualified plan , employee annuity or master trust
- as to the conformance of a prototype trust, custodial account or annuity with the requirements of Traditional IRAs , SEP IRAs , SIMPLE IRAs and Roth IRAs as applicable.
Opinion letters are issued on:
- Initial applications
- Plan amendments
- Master trusts involving the initial acceptability or amendment of such trusts if they are part of qualified plans .
IRM § 188.8.131.52.3 , Revenue Procedure 2000–20
Additional Helpful Information
- Opinion letters are issued by (by the Director of Employee Plans Rulings and Agreements in the Office of the Commissioner, Tax Exempt and Government Entities Division of the IRS
- Opinions letters are not issued for IRS model IRAs, SEPs or SIMPLES