tax qualification

Pension Benefit Guaranty Corporation 74-8 December 23, 1974 RE FERENCE: [*1] 4006(a)( 3) Premium Rates. Initial Rates400 7(a). Payment of Premiums. Due Dates OP INION: This i s a confirmation of the telephone call on November 22, 1974 b y Mr. * * * of our staff regarding the followingquestions: (1) Is a plan covered for purposes of premium payments upon the date it receives a favorable IRSdetermin ation, the date it is established or the e ffective date provided in the pla n documents? (2) If the IRS grants itsdeter mination retr oactive to the plan's effective date, are premiums due for t he interim period and, if so, when are suchpremi ums due? You advise t hat the subject plan was established after Sep tember 1, 1974 with an ef fective date of September 1, 1974and that it is awaiting IRS approval. A plan is covered for the purpose o f premium payments upon the date of establishment or the effective date,whicheve r is lat er. Thus your plan is covered on the date o f establishment, which is normally the dat e on which the plandoc uments are executed. Pre miums are due within 30 days thereafter and should be for the period following such date. Steven E . Schanes Acting Executive Director