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Multiemployer

  • Opinion Letter 82-09

    Addresses the definition of the term "building and construction industry" for purposes of the construction industry exception to withdrawal.

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  • Opinion Letter 83-11

    Addresses whether an employer who contributes to a multiemployer plan withdraws from the plan as a consequence of forming a wholly owned subsidiary which assumes all of its obligations to the plan.

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  • Opinion Letter 83-13

    Addresses the definition of the term "building and construction industry" for purposes of the construction industry exception to withdrawal.

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  • Opinion Letter 87-02

    Addresses the definition of the term “assets” for the purpose of the sale-of-assets exception to withdrawal.

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  • Opinion Letter 91-08

    Addresses post-termination distribution of a multiemployer plan's assets when participants are missing.

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  • Opinion Letter 86-22

    Provides that PBGC approval is not required for a multiemployer plan to adopt a different statutory allocation method for unfunded vested benefits. However, PBGC approval is required for the adoption of an alternative allocation method (i.e. any method other than the four statutory methods).

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  • Opinion Letter 85-03

    Addresses the exclusion of employee contributions in withdrawal liability allocation fractions.

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  • Opinion Letter 83-10

    Regards a statutory provision under which a contributing employer to a multiemployer plan that sells its assets to an unrelated buyer does not withdraw from the plan if (among other things) the buyer posts a bond or escrow and the sales contract makes the seller secondarily liable if the buyer withdraws during the 5 plan years after the sale. Addresses calculation of withdrawal liability of an employer that previously sold some of its assets where, under that statutory provision, the asset sale was not a withdrawal.

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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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