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Withdrawal

Opinion Letter 81-19

Pension Benefit Guaranty Corporation 81-19 July 1, 1981 RE FERENCE: [*1] 4001(b) D efinitions. Employer and Controlled Group4203 Comp lete Withdrawal420 4 Sale of Assets422 5 Limitation on Withdrawal Liability OP INION: Th is is in response to your l etter requesting general guidance concerning the potential withdrawal liability underthe Multi employer Pension Plan Amendments Act of 1980 ("MPPAA") of a construction contractor who sells a tr adeor b usiness in the construction industry.

Opinion Letter 86-04

Pension Benefit Guaranty Corporation 86-4 Februa ry 28, 1986 RE FERENCE: [*1] 4203(a) Complete Withdrawal. Definition of Complete Withdrawal421 8(2) Withdrawal - Suspension of Contributions OP INION: Th is responds to your reque st for the opinion of the Pension Benefit Guaranty Corporation regarding the effect ofsect ion 4218( 2) of the Employee Retirement Income Security Act, as amended (ERISA).

Opinion Letter 83-18

Pension Benefit Guaranty Corporation 83-18 Augus t 5, 1983 RE FERENCE: [*1] 4203 Complete Withdr awal4218(1)(A) Withdrawal - Change of Business Structure OP INION: This resp onds to your request for the opinion of the Pension Benefit Guaranty Corporation concerning the appli cation of Sections 4203 an d 4218 of the Employee Retirement Income Secur ity Act of 1974, 29 U.S.C. § § 1383and 139 8.

Opinion Letter 82-04

Pension Benefit Guaranty Corporation 82-4 Februa ry 10, 1982 RE FERENCE: 4218(1)(A) Withdrawal - Change of Business Structure OP INION: W e have received your let ter in w hich you asked the Pension Benefit Guaranty Corporation ("PBGC") to rule onseveral issues ari sing under the provisions of the Multiemploy er Pension Plan Amendments Act of 1980 (the "Act") asthey apply t o the transactions described in your letter an certain provisions which you propose to include in the sales agreement between the parties i nvolved in those transactions.

Opinion Letter 82-40

Pension Benefit Guaranty Corporation 82-40 December 27, 1982 RE FERENCE: [*1] 4062(d) Liability of Employer in Single Employer Plans. Corporate Reorganizations4203 Comp lete Withdrawal420 4 Sale of Assets4218 W ithdrawal - No occurrence OP INION: This in respo nse to your recent letter to Edwin Jones, regarding secti on 4218 of the Multiemploy er Pension PlanAm endments Act of 1980, which amended the Employee Retirement Income Security Act of 1974.

Opinion Letter 75-116

Pension Benefit Guaranty Corporation 75-116 December 31, 1975 RE FERENCE: [*1] 4041 Termination by Plan Administrator406 3 Liability of Substantial Employer for Withdrawal OP INION: This is in r esponse to your letter of August 28, 1975, regarding the withdrawal of * * * Plan ("the Plan"). Youasked that the Pension Benefit Guaranty Corporation (the "PBGC") determine * * * liabil ity under Section 4063 of theEm ployee Retirement Income Security Act of 1974 ("the Act").

Opinion Letter 83-11

Pension Benefit Guaranty Corporation 83-11 May 16, 1983 RE FERENCE: [*1] 4062(d) Liability of Employer in Single Employer Plans. Corporate Reorganizations4203 Comp lete Withdrawal420 5 Partial Withdrawals4218 W ithdrawal - No occurrence OP INION: This responds to your recent letter req uesting a ruling regarding withdrawal liability under Sections 4203, 420 5 and4218 of t he Employee Retirement Income Secur ity Act of 1974, 29 U.S.C. § 1301 et seq. (1976) (amended by Pub. L.No. 96-36 4 (1980)) ("ERISA").

Opinion Letter 81-32

Pension Benefit Guaranty Corporation 81-32 1981 PBGC LEX IS 9 Septembe r 25, 1981 RE FERENCE: [*1] 4 204 Sale of Assets420 4(a)(1)(B) Sale of Assets. Withdrawal - Posting of Security OP INION: This r esponds to your request for an advisory opinion concerning satisification of the escrow requi rement of Sect ion420 4(a)(1)(B) of ER ISA. Specifically you wish to know whether the deposit of a letter of credit in an escrow account may sa tisfy the requirement. Secti on 4204(a)(1) provi des that a withdrawal fr om a mul tiemployer plan "does not occur solely . . .

Opinion Letter 88-08

Pension Benefit Guaranty Corporation 88-8 May 2, 1988 RE FERENCE: [*1] 4 203(e) - Date of Complete Withdrawal 421 2(a) - Obligation to Contribute - Definitions 421 8(2) - Withdrawal - Suspension of Contributions OP INION: We write in res ponse to your request for an opinion of the Pension Benefit Guaranty Corporation ("PBGC") as tothe date of an empl oyer's withdrawal from a multiemployer pension plan in the construction industry. In particular, youaske d the PBGC for a "clarification" of Opinion Letter 86-4 (Feb.

Opinion Letter 82-17

Pension Benefit Guaranty Corporation 82-17 May 26, 1982 RE FERENCE: 4062(d ) Liability of Employer in Single Employer Plans. Corporate Reorganizations420 4 Sale of Assets421 2(c) Obligation to Contribute - Liability OP INION: We have received y our letter in which you asked the Pension Benefit Guaranty Corporation ("PBGC") to giveadvice on an issue aris ing under the provisions of the Multi employer Pension Plan Amendments Act of 1980 (the "Act")as they ap ply to the transactions described in your letter.

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