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Partial Withdrawal

  • Opinion Letter 85-13

    Addresses the calculation of partial withdrawal liability and why the allocation fraction uses a ratio of contribution base units as opposed to contributions.

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  • Opinion Letter 82-35

    Review of rules governing partial withdrawal as applied to sale of some facilities under CBA.

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  • Opinion Letter 95-03

    Addresses calculation of partial withdrawal credit using the "modified presumptive method" where contributions are averaged over a 10-year period.

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  • Opinion Letter 83-20

    Addresses whether a partial withdrawal occurs when an employer that operates two terminals in a metropolitan area, each under a separate collective bargaining agreement requiring contributions to the same multiemployer plan, closes one terminal but continues to perform the work of the closed terminal through the remaining terminal and other outlying terminals.

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  • Opinion Letter 86-12

    Addresses calculation of the annual withdrawal liability payment amount of an employer that incurred successive partial withdrawals. PBGC subsequently adopted a rule addressing the issue. (See 29 CFR part 4206.)

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  • Opinion Letter 85-16

    Addresses whether or not an 18-month contribution holiday is a partial withdrawal.

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  • Opinion Letter 86-17

    Addresses whether a partial withdrawal occurs when an employer outsources work to a third party.

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  • Opinion Letter 82-22

    This opinion letter addresses the meaning of the term "facility" for purposes of partial withdrawal.

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  • Opinion Letter 92-01

    Addresses the calculation of withdrawal liability in a situation where several members of a controlled group have an obligation to contribute to the same multiemployer pension plan and are sold or liquidated in a series of transactions.

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  • Opinion Letter 82-02

    Addresses what may constitute a complete or partial withdrawal from a multiemployer plan as a result of certain events occurring during contract negotiations; addresses the labor dispute exemption from withdrawal liability.

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