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Nonresident aliens

Opinion Letter 74-06

Pension Benefit Guaranty Corporation 74-6 November 14, 1974 RE FERENCE: [*1] 4006(a)( 3) Premium Rates. Initial Rates402 1(b)(7) Plans Covered. Foreign Plans OP INION: This is in respon se to your recent letter raising a q uestion as whether Canadian participants of a pension plan shouldbe counted for i nsurance premium purposes when the Company maintaining the plan is located in Minneapoli s and hasa sa les office in Canada?

Opinion Letter 80-19

Pension Benefit Guaranty Corporation 80-19 November 13, 1980 RE FERENCE: 402 1(b)(7) Plans Covered. Foreign Plans OP INION: This is in respon se to y our request for a determination by the Pension Benefi t Guaranty Corporation (the "PBGC")as to whether the above plan (the "Plan") is excluded from coverage under Title IV of th e Employee Retirement IncomeSec urity Act of 197 4 (the "Act") by Section 4021(b)(7) of the Act. We have concluded that the Plan is excl uded fromcov erage.

Opinion Letter 74-25

Pension Benefit Guaranty Corporation 74-25 November 8, 1974 RE FERENCE: [*1] 402 1(b)(7) Plans Covered. Foreign Plans OP INION: This is in further repl y to your question regarding the applicat ion of Section 4021(b)(7) of the Employee RetirementInc ome Secu rity Act. It is understood that y our firm, a Canadian company, has branch offices in the United States andoperates two pension plan s. One plan covers staff personnel with approximately 450 Canadian and 48 United Statespartic ipants. The other plan covers agents with approximately 123 Canadian and 5 United States participants.

Opinion Letter 75-42

Pension Benefit Guaranty Corporation 75-42 July 2, 1975 RE FERENCE: [*1] 402 1(b)(7) Plans Covered. Foreign Plans OP INION: This i s in response to your letter of June 13, 1975 asking whether the Canadian participants of the * * * pen sionplan fo r officers and staff should be counted for insurance premium purposes. The Constitution of the * * * provi desthat the Union 's headquarters city is to be Portland, Oregon. Your letter also stated that due to the character of yourorga nization approximately half of the plan participants are Canadian.

Opinion Letter 78-14

Pension Benefit Guaranty Corporation 78-14 June 30, 1978 RE FERENCE: [*1] 402 1(b)(7) Plans Covered. Foreign Plans OP INION: This is in response to your request for a determination whether two pension plans of the * * *, are excl uded fromcoverage under Titl e IV of the Employee Retirement Income Securi ty Act of 1974 (ERISA) by virtue of Section4021(b)( 7) of ERISA.

Opinion Letter 75-53

Pension Benefit Guaranty Corporation 75-53 December 4, 1975 RE FERENCE: [*1] 4021(a) Plans Covered. Requirements of Coverage OP INION: Th is is in response to your N ovember 26, 1974, letter, as supplemented by your telephone conversation with * * * of this Corporation on November 20, 1975, regarding the coverage status of the * * * (the "Plan") under Title IV ofthe E mployee Retirement Income Security Ach of 1974 (the "Act"). We unde rstand that the Plan has not been determined by the Internal Revenue Service to be a qualified plan as described below.

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