IRS EXTENDS RELIEF FOR PLANS INVESTED IN TROUBLED INSURANCE COMPANIES.

Rev. Proc. 94-19

SECTION 1. PURPOSE

The purpose of this revenue procedure is to extend the closing date of the temporary closing agreement program described in Rev. Proc. 92-16, 1992-1 C.B. 673, as modified by Rev. Proc. 93-14, 1993-1 C.B. 485, to settle certain tax liabilities that arise out of transactions between an employer-sponsor and the trust of a qualified defined contribution plan.

SEC. 2. BACKGROUND

.01 Section 3 of Rev. Proc. 92-16 sets forth a temporary closing agreement program that was scheduled to expire on February 1, 1993. The temporary closing agreement program is available to an employer that makes conditional payments to its otherwise qualified defined contribution plan on account of plan assets that are invested in certain contracts issued by a life insurance company within the meaning of section 816(a) of the Internal Revenue Code that has been placed in state insurer delinquency proceedings.

.02 Section 3 of Rev. Proc. 93-14 extends the program described in section 2.01 above and states that requests for closing agreements must be submitted to the National Office of the Internal Revenue Service on or before February 1, 1994.

SEC. 3. EXTENSION OF TEMPORARY CLOSING AGREEMENT PROGRAM

The temporary closing agreement program described in Rev. Proc. 92-16 is extended to requests for closing agreements submitted to the National Office of the Internal Revenue Service on or before February 1, 1995.

SEC. 4. EFFECT ON OTHER DOCUMENTS

Rev. Proc. 92-16 is modified and Rev. Proc. 93-14 is superseded.

SEC. 5. EFFECTIVE DATE

This revenue procedure is effective February 2, 1994.

DRAFTING INFORMATION

The principal author of this revenue procedure is Michael Rubin of the Employee Plans Technical and Actuarial Division. For further information regarding this revenue procedure, please contact the Employee Plans Technical and Actuarial Division's taxpayer assistance telephone service or Mr. Rubin between 1:30 and 4:00 p.m., Eastern time, Monday through Thursday on (202) 622-6074/6075 or (202) 622- 6214, respectively. Neither telephone number is toll-free.