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Multiemployer

  • Opinion Letter 83-17

    Pending regulations, plans have the ability to adopt reasonable rules to abate an employer’s withdrawal liability.

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  • Opinion Letter 95-02

    Addresses the interpretation of the special rule for partial withdrawals for certain employers and plans in the building and construction industry.

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  • Opinion Letter 89-02

    Addresses (1) whether transfers of contributions between multiemployer plans under a reciprocity agreement are covered by rules on transfers of assets; and (2) whether a reciprocity agreement can create withdrawal liability obligations.

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  • Opinion Letter 83-19

    Addresses whether, under the presumptive method of allocating withdrawal liability, if a plan's assets exceed its vested liabilities, the unfunded vested benefit amount is zero.

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  • Opinion Letter 85-15

    Addresses whether the rule against transactions with a principal purpose to avoid withdrawal liability can apply when a transaction meets the sale of assets exception requirements.

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  • Opinion Letter 93-02

    Discusses the calculation of partial withdrawal liability following a 70 percent decline in contributions.

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  • Opinion Letter 87-08

    Addresses whether a contributing employer to a multiemployer plan withdraws by subcontracting out its work to another contributing employer such that contributions are unaffected.

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  • Opinion Letter 81-27

    Addresses the special rules governing a transfer between multiemployer plans where an employer withdraws from a plan because the union bargaining with that employer has been changed as a result of the certification of a different union.

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  • Opinion Letter 85-01

    Addresses interest factors applicable to withdrawal liability installments paid other than quarterly.  Corrected by Opinion Letter 85-18.

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