Pension & Benefits News IRS updates technical advice memoranda procedures
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Wednesday, January 23, 2019

IRS updates technical advice memoranda procedures

By Pension and Benefits Editorial Staff

The IRS has issued its annual revision of the general procedures relating to the issuance of technical advice to a director or an appeals area director by the various offices of the Associate Chief Counsel. The procedures also explain the rights a taxpayer has when a field office requests technical advice. A technical advice memorandum (TAM) is normally requested when there is a lack of uniformity regarding the disposition of an issue or when an issue is unusual or complex enough to warrant consideration by an Associate office.

Few significant changes have been made to the procedure. The mandatory TAM requirement in qualified retirement plan matters in cases concerning proposed adverse letters or proposed revocation letters on collectively bargained plans has been deleted. In addition, it has been clarified that requests for relief under Code Sec. 7805(b) relating to the revocation or modification of determination letters and letter rulings issued by TE/GE are handled under the procedures in sections 23 and 29 of Rev. Proc. 2019-4 and section 12 of Rev. Proc. 2019-5.

Rev. Proc. 2019-2 is effective January 2, 2019.

SOURCE: Rev. Proc. 2019-2 will be reproduced in a future Report at ¶17,299V-96.

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