| 98-2 |
| May 20, 1998 |
| REFERENCE: |
| 4021(b)(2) Plans Covered. Government Plans |
| OPINION: |
| This is in response to the request that you filed (the "Request") n1 for a determination by the Pension Benefit Guaranty |
| Corporation ("PBGC") that the above-referenced plan (the "Plan") is exempt from coverage under Title IV of ERISA, 29 |
| U.S.C. § 1301, et seq. You assert that the Plan is a governmental plan that is exempt under ERISA § 4021(b)(2). For |
| the reasons discussed below, on the basis of the information that you provided, we conclude that the Plan is not a |
| n1 Our references to the "Request" include your letters dated September 8, 1995 ("Sept. Ltr."); January 5, 1996 ("Jan. |
| Letter"); April 26, 1996 ("Apr. Ltr."); and July 21, 1997 ("July Ltr."), and attachments thereto. In addition, you have provided |
| PBGC counsel in telephone conversations with certain background information. |
| The Request |
| The Plan sponsor is * * * (the "Corporation"), a * * * corporation that, under a contract with the city of * * * (the "City"), |
| operates the * * * (the "Transit System"). The Request argues that the Corporation is a government instrumentality, and |
| thus the Plan is a governmental plan exempt from Title IV coverage. Apr. Ltr. at 1. |
| In support, the Request asserts that the governmental exemption applies because: (1) the Corporation "operates the City's |
| transit system" (Sept. Ltr.); (2) the City "owns" the Transit System, which is a "public enterprise" within the meaning of |
| N.C. Gen. Stat. § 160A-311 (Apr. Ltr. at 1-2); (3) the City is the "source" of contributions to the Plan, and, under its |
| contract with the Corporation, is responsible for paying "all past, present, and future pension or profit-sharing plan liability, |
| including, without limitation . . . liability for vested, but under funded or unfunded benefits" (id. at 2-3, 4); (4) in-house |
| counsel for * * * ., the ultimate parent of the Corporation, wrote a letter to the Corporation opining that the Corporation "and |
| similar subsidiaries of * * * " are government instrumentalities (id. at 3); (5) the City pays all expenses of the Transit |
| System, and all revenues therefrom are property of the City (id. at 4); (6) the City has the power to approve in advance |
| the appointment and removal of the "resident management team" of the Corporation's parent, * * * (id.); (7) the |
| Corporation's activities are greatly restricted by the policies, standards and procedures established by the City (id.); (8) |
| the Plan is a governmental plan within the meaning of Title I of ERISA, § 3(32) (id. at 5); and (9) the Plan is a |
| governmental plan within the meaning of the Internal Revenue Code, § 414(d) (id. at 5-7). n2 |
| n2 The Request included the following documents: (1) selected sections of the City's Charter and * * * General Statutes; |
| (2) the Corporation's Articles of * * * Incorporation; (3) various reports and internal draft and final memos of the City |
| pertaining to standards applicable or desirable for the Transit system; (4) the "opinion letter" dated March 26, 1996, of * * * |
| , Assistant Division Counsel, * * * .; (5) the management contract dated September 1, 1994, among the Corporation, * * * , |
| and the City; (6) Form 5303 Application for plan qualification to the IRS dated March 31, 1995, (7) IRS Determination |
| Letters dated August 15, 1988, December 7, 1995, and undated but mailed in February 1996; (8) Plan counsel's letter to |
| the IRS dated January 5, 1996; and (9) the Plan. |
| Background |
| The City is a political subdivision of the State of * * * . Apr. Letter at 1-2. Pursuant to state statute, the City is authorized |
| to contract for the operation of a "public enterprise" such as the Transit System. N.C. Gen. Stat. § § 160A-311, 312(a). |
| As we understand the facts, from 1955 to 1977, the Transit System was managed by * * * was a private, for-profit |
| corporation that was owned, directly or indirectly, by a private company based in * * * . See Plan at § 1.6. * * * managed |
| the Transit System under contract with the City. In 1955, * * * established a pension plan for employees of the Transit |
| System (the " * * * Plan"). The Request does not assert that the * * * Plan was or is a governmental plan or otherwise |
| In 1977, the City did not extend the management contract with * * * and instead selected the Corporation and * * * |
| Company to manage the Transit System. The Corporation, organized under the laws of * * * , is a subsidiary of * * * |
| Company (the "Parent"), a wholly owned, for-profit subsidiary of * * * ., a wholly owned subsidiary of * * * ., which is a |
| wholly owned subsidiary of * * * . The Parent is in the business of providing management services for the operation of |
| Certain employees who work in the Transit System are represented by the * * * (the "Union"). When * * * was replaced by |
| the Corporation, the City and Union agreed that the pension benefits of Transit System employees should not be affected |
| by the replacement of the management company. They attempted to obtain the agreement of * * * to transfer assets |
| allocable to those employees from the * * * Plan to a successor plan to be established. However, * * * refused their |
| Instead, the City and the Corporation established the Plan as a type of mirror, offset benefit plan that, in combination with |
| the * * * Plan, essentially provided the benefits that would have been paid had the participants continued to be covered by |
| the * * * Plan. From 1980 to 1995, without reservation, the Plan paid Title IV premiums. n3 |
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n3 Under ERISA § § 4006 and 4007, only plans covered by Title IV are required to pay premiums. Governmental plans |
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are not required to pay premiums to PBGC. See ERISA § § 4006(a)(1) and 4021(b)(2). |
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The Plan is not part of any pension plan offered by the City to public employees. Apr. Letter at 2; Plan § 12.2. The Plan |
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provides that the Corporation (and not the City) is the sponsor of the Plan. See Plan § § 1.8, 2-5, 8, 10-12. Under Plan § |
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3.1, the Corporation is required to make such contributions "as are deemed necessary to maintain the Plan on a sound |
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actuarial basis . . . taking into account . . . the requirements of the [Internal Revenue] Code." n4 |
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n4 Minimum funding requirements prescribed by Title I of ERISA and section 412 of the Code do not apply to |
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"governmental plans" within the meaning of those statutes respectively. ERISA § 4(b)(1); Code § 412(h)(3). Thus, if the |
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Plan were * * * governmental, no contributions would be required under ERISA or section 412 of the Code. |
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Participation in the Plan is limited to Corporation employees. Plan § § 1.5, 2.1. Although the Plan grants past service |
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credit for employment with private companies such as * * * , it does not grant past service credit for employment with the |
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City. Plan § § 1.17, 1.31. |
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The Corporation administers the Plan. Plan § 8.1. The Corporation is empowered to appoint and remove the Trustee, who |
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manages the assets of the Plan. Plan § 9.7. |
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The Corporation has the exclusive powers, unrestricted by the Plan, to amend and terminate the Plan. Plan § § 10.1, |
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10.2. Upon termination of the Plan, any excess assets revert to the Corporation. Plan § § 3.2, 10.2(c). The Plan also |
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provides that "no participant or other individual shall have recourse toward the satisfaction of any accrued benefit other |
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than from the trust fund or the Pension Benefit Guaranty Corporation." n5 Plan * * * § 10.2(b). |
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n5 Under ERISA § 4021(b)(2), PBGC does not guarantee benefits of governmental plans. |
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The contract dated September 1, 1994, among the Corporation, the Parent; and the City (the "Contract"), § I.A., provides |
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that the City "engages [the Parent and the Corporation] as independent contractors to advise the City and manage the |
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operation of its transit system . . . . now or hereinafter owned by the City." (Emphasis added.) "The Parent and the |
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Corporation are * * * independent contractors and are not employees or agents of the City and each retains the right to |
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exercise full and exclusive control and supervision over its employees and their compensation and discharge except as |
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herein provided." Contract § I.A.1. The Contract further provides it shall not "be construed as creating a partnership, |
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agency, joint venture or other similar relationship between the City and [the Parent] or [the Corporation]." Contract § I.A.1. |
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The Parent is to be compensated by the City for its management services in the amount of at least $ * * * per annum, |
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plus incentives and other charges not to exceed $ * * * over three years, not including "Special Projects." Contract § I.B.4. |
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The Corporation is "responsible for operating the [Transit System] under the supervision of [the Parent] and subject to the |
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policy direction of the City. . . ." Contract § I.A.1. Subject to the consent of the City, the Parent appoints and removes |
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certain senior management personnel. Contract § II.A.1. The Parent and Corporation together "have primary responsibility |
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to manage all primary and support functions necessary to transit operations." Contract § II. In particular, management |
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responsibilities of the Parent and the Corporation include: |
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. . . carrying out the functions of short range transit planning, equipment and building utilization and maintenance, security, |
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routes, schedules, fare analysis, equal service standards, purchasing, budgeting, safety, employee selection and training, |
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employee relations, labor negotiations, public relations, equipment selection, development of all specifications, capital |
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equipment and capital improvements, unless the City desires to make other arrangements, and all other normal managerial |
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functions reasonably required in the day-to-day operation of [the Transit System] . . . . [Contract § I.B.1.] |
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The City has "primary responsibility for policy direction, funding, marketing, finance, and grant application/administration |
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and long range planning for Transit System operations." Contract § II. The City owns all or virtually all of the hard assets |
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of the Transit System, as well as the operating revenue. Contract § § III.C, V.B. In addition, the City is responsible for |
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paying "all operating expenses" of the Transit System, which includes "[c]ontributions to a pension plan that meets Federal |
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requirements pursuant to [the] Employee Retirement [sic] Security Act of 1974" and "all past, present, and future pension |
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or profit sharing liability, including, without limitation to [sic] liability for vested, but under funded or unfunded benefits." |
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Contract § I.A.2.b. Upon termination or expiration of the Contract, "the City or its designee shall . . . immediately assume |
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responsibility for the payment and performance of all outstanding obligations arising out of the [Corporation] employment |
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relationship, including, but not limited to, . . . pension or profit sharing plans, including, without limitation, liability for |
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vested but unfunded or underfunded benefits." Contract § III.A.2. |
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The Request does not assert, and the Contract does not provide, that the City is directly liable to the Plan or Plan |
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participants for unfunded benefits. The Contract contains no provision allowing Plan participants to enforce a claim against |
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either the Corporation or the City with respect to any Plan benefit or liability. Although Plan counsel suggested that |
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participants may have a third-party beneficiary claim against the City, the Contract explicitly provides that it "is not |
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intended to be a third party beneficiary contract and confers no rights upon anyone other than the City or [the Parent]/[the |
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Corporation]." Contract § III. I. Nor is there any statute that requires the City to contribute to the Pension Plan in the |
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event of underfunding. Apr. Letter at 3. In substance, the Contract merely provides for indemnification of the Corporation |
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by the City, rather than unconditionally obligating the City to pay for unfunded benefits. |
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In addition, Section 11.2 of the Plan provides that the Corporation is not liable thereunder for any Plan benefits. Thus, |
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even if the City were, under the Contract, vicariously liable to the participants for the Corporation's Plan benefit liabilities, |
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the Corporation has no such liabilities under the Plan. The City's buffer against liability for Plan benefits is further |
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reinforced by Plan Section 11.2, which provides that no benefits are payable except in accordance with the Plan, and, as |
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previously noted, the Plan makes no provision whatsoever for payment of any benefits or liabilities by the City. n6 In |
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sum, if the Plan were governmental, the Corporation would not be liable for unfunded benefits upon termination of the Plan, |
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and, thus, the City would not even have indemnification liability with respect to unfunded benefits. |
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n6 Further, under Plan § 11.7, only the Corporation and the Trustee are necessary parties to litigation involving the Plan, |
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and participants, who are purportedly bound by such litigation under the terms of the Plan, are not entitled to any notice of |
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such litigation. |
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The Request does not assert that the Corporation is treated as a governmental entity under any state or other federal law. |
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Nor does the Request assert that employees of the Corporation are treated as government employees. To the contrary, |
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as previously noted, the Contract provides that the Corporation, and not the City, controls the compensation, discipline |
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and day-to-day functions of employees who operate the Transit System. Contract § § I.A.1, I.A.2.a. |
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The Request suggests that the IRS's favorable qualification letter of * * * , may support the Request because the IRS's |
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letter refers to the Plan as a governmental plan. n7 However, as the Request concedes, the IRS expressly disclaimed |
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having considered whether the Plan met the requirements for governmental plan status. Further, by letter dated January 5, |
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1996, Plan counsel requested the IRS to issue a "corrected determination letter" without the disclaimer of consideration of |
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the Plan's governmental status. However, on * * * , the IRS instead issued a revised determination that eliminated the |
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reference to the Plan as a governmental plan. |
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n7 In a telephone conversation, Plan counsel told PBGC counsel that the IRS had determined the Plan to be a |
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governmental plan. However, after PBGC counsel requested a copy of the IRS's determination, Plan counsel reviewed the |
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matter and, in his * * * cover letter to PBGC counsel, receded from the position that the IRS had determined that the Plan |
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was governmental. The Request also relies upon the "opinion letter" dated March 26, 1996, of * * * , Assistant Division |
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Counsel of * * * (the " * * * Opinion"). It states that "has always taken the position" that the Plan is governmental based |
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upon various private letter rulings of the IRS and the opinion of outside counsel. The * * * Opinion asserts that the IRS has |
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taken the position in private letter rulings that employees of transit operations like those of the Transit System are |
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"actually governmental employees" and therefore the benefit plans covering them are governmental plans. However, the * |
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* * Opinion does not include or specifically reference such private letter rulings. Moreover, neither the * * * Opinion nor the |
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Request asserts that a private letter ruling as to whether the Plan is governmental has ever been requested of the IRS. |
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Similarly, neither the * * * Opinion nor the Request includes the "opinion of outside legal counsel" upon which the * * * |
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Opinion relies. |
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Discussion |
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ERISA § 4021(b)(2), 29 U.S.C. § 1321(b)(2), excludes from Title IV coverage any plan "established and maintained for |
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its employees by the Government of the United States, by the government of any State or political subdivision thereof, |
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or by any agency or instrumentality of any of the foregoing . . ." The legislative history of ERISA § 4021(b)(2) indicates |
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that * * * governmental plans were excluded from Title IV coverage because, in part, Congress believed that "the ability of |
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governmental bodies to fulfill their obligations to employees through their taxing powers is an adequate substitute for |
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termination * * * insurance." S. Rep. No. 93-383, 93rd Cong., 1st Sess., 81 (1973); H.R. Rep. No. 93-807, 93rd Cong., 2d |
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Sess, 164-5 (1974). See Rose v. Long Island R.R., 828 F.2d 910 (2d Cir. 1987); PBGC Op. Ltr. 75-44. |
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There is no definitive statutory or regulatory definition of the term "governmental instrumentality." PBGC has considered a |
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number of factors in determining whether a plan is or is not the plan of a governmental instrumentality. These include (i) |
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whether the plan or the plan sponsor is controlled by a governmental entity, (ii) whether the officers or members of the |
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plan sponsor represent, or are selected by, a governmental entity, (iii) whether the plan or the plan sponsor is funded by a |
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governmental entity, (iv) whether the plan's participants are treated as governmental employees, (v) whether the plan |
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sponsor is treated under state or federal law as a governmental entity, (vi) whether there are any private interests |
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involved, and (vii) whether a governmental entity has the powers and interests of an owner. See, e.g., PBGC Opinion |
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Letters No. 83-16 (July 12, 1983), No. 81-40 (December 9, 1981), No. 81-37 (November 16, 1981), No. 81-31 (September |
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22, 1981), No. 81-30 (September 22, 1981), No. 81-13 (May 13, 1981), No. 79-6, (April 10, 1979), No. 78-25 (October 31, |
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1978), No. 77-152 (July 13, 1977), and No. 76-95 (August 2, 1976). |
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Based upon the statute, its legislative history, and the criteria discussed in these Opinion Letters, we do not agree that the |
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facts presented by the Request show that the relationship between the Corporation and the City is such that the |
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Corporation should be deemed a governmental instrumentality for purposes of section 4021(b)(2) of ERISA. |
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(i) Control. First, the Request does not demonstrate that the City exercises control over the Plan. To the contrary, the Plan |
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is sponsored and administered solely by the Corporation and the Corporation's appointee, the Trustee. Second, the * * * |
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Corporation itself is owned and controlled by the Parent, a private, for-profit corporation, rather than the City. Indeed, the |
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Corporation's Charter makes no mention whatever of the City. Third, by contract, the Corporation is "an independent |
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contractor" rather than any form of "agent" of the City. Of course, like virtually any client, the City establishes the overall |
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goals of its contractor, the Corporation, with respect to the subject of the contract. However, the Corporation and the |
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Parent are substantially responsible for how they perform their contractual tasks. Thus, the Parent and the Corporation are |
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contractually authorized and directed "to manage all primary and support functions necessary to transit operations." Fourth, |
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the Request does not demonstrate that, in practice, the City actually manages those functions while the Corporation and |
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the Parent perform merely ministerial functions. In sum, the evidence provided by the Request indicates that the Plan is |
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controlled by the Corporation, which in turn is owned and substantially controlled by private interests, the * * * , rather than |
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by the City. See PBGC Op. Ltrs. 81-2 and 81-13. |
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(ii) Officers and Directors. The Parent, under the Contract and by its control over the Corporation, has "primary" |
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responsibility for managing the Transit system. The Request does not demonstrate that the City has the power of |
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appointment of the officers or directors of the Parent. n8 Moreover, the Parent, and not the City, appoints the officers and |
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directors of the Corporation. See Rose v. LIRR, 828 F.2d 910, 916-917 (2d Cir. 1987); PBGC Op. Ltrs. 81-23, 81-30, and |
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n8 Under Contract § II.A.1., the Parent is responsible for furnishing a "resident management team" that must be approved |
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by the City. However, at least absent a demonstration that the City's veto power, in practice, amounted to a power of |
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appointment, this provision cannot be equated with a power of appointment. Rather, it appears simply to be a typical |
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provision in service contracts intended to assure that, for key positions, the managing company selects from its staff |
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those employees who have appropriate expertise and experience. |
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(iii) Funding. Under the Plan, the Corporation, which does not have taxing power, is solely responsible for Plan |
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contributions. Although the City is contractually liable to the Corporation for reimbursement of those contributions, the |
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Request does not demonstrate that the City would be liable to the Plan or the participants for delinquent contributions. |
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Moreover, the Request does not demonstrate that the City would necessarily be liable for underfunding if the Plan were |
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terminated. See PBGC Op. Ltr. 81-13 (plan was not governmental where contractor/plan sponsor's contract with the |
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government provided that wages and pension contributions attributable to work performed for the governmental project |
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were an "allowable expense," but "[n]either the Plan nor the contract provides for any direct payment by [the governmental |
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entity] of Plan participant benefits in the event they become unavailable from other funding media)." See also PBGC Op. |
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Ltr. 76-95. Compare PBGC Op. Ltr. 77-126 (plan is governmental where governmental entity "is contractually required to |
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pay all benefit entitlements under the Plan, including, in the event of a termination, benefits that would be insured under |
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(iv) Employee Status. The Request makes no showing that Transit System employees are government employees of the |
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City, rather than private employees of the Corporation. And, under the Contract, the Corporation "retains the right to |
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exercise full and exclusive control and supervision over its employees and their compensation and discharge . . . ." See |
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Alley v. Resolution Trust Corp., 984 F.2d 1201, 1205-6 (D.C. Cir. 1993) (court found no indication that Congress meant the |
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ERISA exemption to reach an entity whose employees are not subject to laws governing public employees generally, |
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since "the core concern for ERISA purposes is the nature of an entity's relationship to and governance of its employees"); |
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(v) Other Laws. The Request does not assert or demonstrate that the Corporation is treated as a governmental entity |
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under any other federal or state law. See PBGC Op. Ltrs. 81-23, 81-30, and 81-37. |
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(vi) Private Interests. The Corporation is a wholly owned subsidiary of the Parent, which in turn is a wholly owned affiliate |
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of the privately owned * * * . Thus, the Corporation is owned and controlled by private, commercial interests. See Rose v. |
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LIRR, 828 F.2d at 915; PBGC Op. Ltr. 81-13. |
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(vii) Governmental Interests. The City owns the assets and revenues of the Transit System and is responsible for most |
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Transit System expenses. Moreover, the Transit System serves a public purpose. However, as noted above, the Plan is |
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sponsored by the Corporation, which is owned and controlled by the * * * , not the City. The Corporation's employees are |
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not covered by any of the City's plans. See Alley v. RTC, 984 F.2d at 1206 (Congress assumed that public employees |
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exempt from ERISA protection would be "covered by some distinctively 'public' employee benefit scheme.") |
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In sum, we conclude that the various factors used to assess whether the Corporation is a governmental instrumentality |
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weigh heavily towards the conclusion that it is not, and thus that the Plan is not a governmental plan exempted from Title |
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IV protection and coverage. Further, we do not think that the arguments raised by the Request support a different |
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First, the Request asserts that the governmental exemption applies because the Corporation "operates the City's transit |
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system," which is a "public enterprise" within the meaning of N.C. Gen. Stat. § 160A-311. (Apr. Ltr. at 1-2; Sept. Ltr.) The |
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fact that a private entity's operations serve a public purpose does not convert the entity into a governmental |
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instrumentality. See Alley v. RTC, 984 F.2d at 1205. Indeed, many clearly private companies provide public |
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transportation, support national defense efforts, or otherwise serve public purposes. See PBGC Op. Ltr. 81-13. Thus, the |
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fact that the operations of the Corporation serve a public purpose does not establish that the Corporation is a government |
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Second, the Request asserts that the governmental exemption applies because the City "owns" the Transit System. (Apr. |
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Ltr. at 1-2.) However, although the City owns the hard assets, the Corporation, and not the City, employs the Transit |
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System employees and sponsors the Plan. |
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Third, the Request asserts that the Plan is exempt because the City is the "source" of contributions to the Plan, and, under |
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its contract with the Corporation, the City is responsible for paying "all past, present, and future pension or profit-sharing |
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plan liability, including, without limitation . . . liability for vested, but under funded or unfunded benefits." (Apr. Ltr. at 2-3, |
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4.) However, as previously discussed, the Request does not demonstrate that the taxing power of the City necessarily |
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backs the obligations of the Plan. |
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Fourth, the Request relies upon the * * * Opinion that the Corporation "and similar subsidiaries of * * * " are government |
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instrumentalities. (Apr. Ltr. at 3.) However, the * * * Opinion is merely conclusory. Rather than presenting substantive |
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support for the position that the Corporation is a governmental instrumentality, the * * * Opinion relies upon unspecified |
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private letter rulings by the IRS and an undisclosed opinion by * * * 's "outside legal counsel." Plainly, the weight of the |
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evidence that the Corporation is not a governmental instrumentality is not affected by conclusory, unspecified, or |
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undisclosed rulings or opinions. Moreover, the * * * Opinion is expressly based upon the proposition that "the employees of |
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[the Corporation] . . . are government employees and the corresponding benefit plans are government plans." However, |
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as previously discussed, the evidence submitted with the Request does not support the conclusion that the Corporation's |
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employees are government employees. While this may not necessitate a finding that the Plan is private in all |
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circumstances, it negates the * * * Opinion's only stated basis for its position that the Plan is governmental. |
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Fifth, the Request suggests that the Corporation is a mere conduit controlled by the City because the City pays all |
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expenses of the Transit System and all revenues thereof are property of the City (id. at 4); the City has the power to |
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approve the appointment and removal of the "resident management team" of the Corporation's parent, * * * (id.); and the |
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Corporation's activities are greatly restricted by the policies, standards and procedures established by the City (id.). |
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However, Request does not demonstrate that the Corporation is a mere conduit or agent of the City. |
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To the contrary, the Contract between the Corporation and the City provides that the Corporation is independent from the |
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City with regard to performance of its duties thereunder, namely, the operation of the Transit System. For example, the |
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Contract specifies that the Corporation is an independent contractor rather than any kind of agent of the City. Moreover, |
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under the Contract, the Corporation "retains the right to exercise full and exclusive control and supervision over its |
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employees and their compensation and discharge. . . ." And while the City is primarily responsible for basic policy choices |
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and funding, the Corporation and the Parent are responsible for operating the Transit System. |
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Finally, the Corporation is a wholly owned affiliate of a large, well established, privately controlled group of corporations, * |
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* * , that is in the business, inter alia, of operating transit systems. This kind of independent ownership is further evidence |
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that the Corporation is not a mere conduit that is controlled by the City. |
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Sixth, the Request asserts that the Plan is a governmental plan within the meaning of Title I of ERISA, § 3(32). (Apr. Ltr. |
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at 5). However, this is far from clear. The Department of Labor considers much the same factors as PBGC in determining |
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coverage under ERISA § 3(32). See DOL Opinion Letter 90-09 (April 25, 1990). As previously discussed, those factors |
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indicate that the Plan is not a governmental plan. Indeed, the Request does not assert that an opinion of DOL concerning |
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the Plan or any other plan of the Corporation was ever requested or issued. |
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Moreover, the DOL opinion letters cited by the Request do not support the conclusion that the Plan is a governmental plan. |
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DOL Opinion Letter 93-28A involved a city transportation authority (the "Authority") that was established as a "public body" |
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by state statute. This public body was empowered to levy and collect taxes, to issue municipal bonds, and exercise the |
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right of eminent domain. Its employees were treated as public employees for purposes of workers' compensation statutes. |
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The board of directors of the Authority was appointed by public officials. The plan at issue was sponsored and |
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administered by the Authority. Thus, the DOL's conclusion that the Authority's plan was a governmental plan provides no |
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support for the Request's position that the Plan at issue here is governmental. To the contrary, DOL carefully |
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distinguished the Authority's governmental plan from a different plan, evidently non-governmental, maintained by a private |
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company engaged by the Authority to provide drivers and maintenance personnel for the bus system. n9 |
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n9 Similarly, DOL Op. Ltr. 95-21A does not support the Request. That letter involved a plan sponsored and administered |
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by a county-owned hospital. The hospital was operated pursuant to state statute by the county. The hospital's powers |
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included the power to levy taxes, to issue tax-exempt bonds, and to exercise the right of eminent domain. The county was |
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responsible for the financial obligations of the hospital. The hospital's board was appointed by public officials. DOL |
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specifically cited these governmental powers and control in concluding that the hospital was a governmental entity. In |
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contrast, the Corporation does not have such powers, nor is it publicly owned or controlled as was the hospital. Thus, if |
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anything, DOL Op. Ltr. 95-21A supports the conclusion that the Plan is not governmental. Finally, even if the Plan were |
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governmental under Title I, that would not be conclusive here. Although DOL is entitled to deference in its interpretations of |
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Title I of ERISA, those interpretations do not necessarily control in the Title IV context. |
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Seventh, the Request asserts that the Plan is a governmental plan within the meaning of the Internal Revenue Code, § |
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414(d). (Apr. Ltr. at 5-7). As previously noted, however, the Request does not assert that a ruling to that effect was |
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requested or issued by the IRS. To the contrary, in response to Plan counsel's January 5, 1996 letter, the IRS refused to |
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certify that the Plan was governmental. |
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The Request also cites certain IRS Revenue Rulings and private letter rulings as to other plans, but these rulings are not |
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persuasive that the Plan is a governmental plan within the meaning of ERISA § 4021(b)(2). Revenue Ruling 57-128, 1957- |
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1 C.B. 311, was a pre-ERISA, non-pension ruling involving an association operated by the heads of the insurance |
|
departments of several states, all members of which were public officials. Moreover, in that case, the IRS opinion that the |
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association was governmental was based upon the fact that "no proprietary interest in the association exists other than |
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those of the states themselves, which through the membership of their officers have the powers and interests of an |
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owner." Here, in contrast, the Parent and the Corporation are owned by the * * * . n10 |
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n10 Similarly, Rev. Rul. 65-196, 1965-2 C.B. 388, was a pre-ERISA, non-pension ruling involving a government-owned and |
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controlled sports commission created to provide recreational facilities for the public. |
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More to the point is Rev. Rul. 89-49, 1989-1 C.B. 117, n11 in which the IRS ruled that a plan sponsored by a non-profit |
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company that contracted to provide volunteer fire-fighting services to several municipalities was not a governmental plan. |
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The IRS stated that "one of the most important factors . . . is the degree of control that the . . . government has over the |
|
organization's everyday operations." Further, the IRS stated that "the mere satisfaction of one or all of the factors is not |
|
necessarily determinative." In particular, the IRS found that: |
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[t]he degree of control which the municipalities exert over the fire company in its everyday operations is * * * minimal. . . |
|
. [T]here was no specific legislation which affiliated the company with the state. Further, the company's expenses are, in |
|
part, paid by the community donations. In addition, the board of trustees which controls the company's basic operation is |
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elected by the volunteer fire-fighters. Finally, State X has not treated the company's employees as employees of the |
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state or political subdivision thereof. |
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Similarly, in the instant case, the Request has not established that the City substantially controls the day-to-day operation |
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of the Transit System, or that it treats the Corporation's employees as City employees. Moreover, the evidence here as |
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to the other factors noted by the IRS is comparable to the evidence in that case. n12 |
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n11 Unlike Rev. Rules 57-128 and 65-196, supra, Rev. Rul. 89-148 was issued under section 414(d) of the Code and is the |
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published position of the IRS with respect to this ERISA-correlated section of the Code. |
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n12 In PLR 7935040 (May 29, 1979) and PLR 9541040 (June 30, 1995), on facts similar to the instant case in certain |
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respects, it was determined that plans of certain corporations that manage transit systems under contract with a city or a |
|
city instrumentality were governmental plans. However, unlike the instant case, in those cases there was no finding that |
|
the cities were not directly liable for pension liabilities. Moreover, unlike the instant case, the IRS found that the cities |
|
exercised substantial control over the everyday operations of the managing corporation. Here, in contrast, the facts show |
|
that the Corporation's functions are not merely ministerial. Moreover, a private letter ruling applies only to the taxpayer(s) |
|
to whom the private letter ruling is issued. And, in any event, even if the two IRS cases were factually identical to the |
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instant case, PBGC might well reach a different conclusion under Title IV than those two private letter rulings reach under |
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the Code. In sum, the IRS rulings cited by the Request do not persuade us that the Plan is a governmental plan under Title |
|
Conclusion |
|
For the reasons discussed above, we conclude that the Plan is not excluded from coverage under Title IV of ERISA as a |
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governmental plan. PBGC's Collections and Compliance Division will contact you regarding due and owing premiums and |
|
associated interest and penalties. |
|
This letter constitutes an initial determination of which reconsideration may be requested pursuant to 29 C.F.R. Part 4003. |
|
Absent such a request for reconsideration, your client's administrative remedies would not be exhausted. If you decide to |
|
request reconsideration, the request should be sent, within 30 days of the date of this letter, to: |
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Anna Gilreath |
|
Manager |
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Standard Termination and Compliance Division |
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Insurance Operations Department |
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1200 K St., N.W. |
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Washington, D.C. 20005-4026 |
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This letter is not a determination as to the applicability to the Plan of either Title I or Title II of ERISA. Any inquiry relating |
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to such a determination should be directed to the Department of Labor or the Internal Revenue Service, respectively. |
|
Charles Korb |
|
Manager |
|
Processing and |
|
Technical Assistance Branch |