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Multiemployer

  • Opinion Letter 82-24

    Review of rules governing plan administration after mass withdrawal; modification of withdrawal liability payment schedules; and recharacterization of contributions as withdrawal liability payments.

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  • Opinion Letter 88-03

    Addresses the legal effect of PBGC approval of a multiemployer plan amendment.

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  • Opinion Letter 82-38

    Addresses whether officers or shareholders may be held liable for a corporation’s withdrawal liability.

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  • Opinion Letter 87-13

    Addresses issues concerning the merger of a multiemployer defined benefit plan with a defined contribution plan.

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  • Opinion Letter 91-07

    Addresses the ability of an employer challenging its withdrawal liability assessment, to raise additional issues for review by the multiemployer plan, or in arbitration, after making its initial submission.

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  • Opinion Letter 90-01

    Addresses whether a withdrawal from a multiemployer plan will be triggered by various circumstances occurring after a 4204 sale of assets such as a second subsequent sale or a change in corporate structure.

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  • Opinion Letter 86-17

    Addresses whether a partial withdrawal occurs when an employer outsources work to a third party.

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  • Opinion Letter 82-22

    This opinion letter addresses the meaning of the term "facility" for purposes of partial withdrawal.

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  • Opinion Letter 87-01

    Addresses the circumstances under which a bankruptcy proceeding may give rise to withdrawal liability.

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  • Opinion Letter 92-01

    Addresses the calculation of withdrawal liability in a situation where several members of a controlled group have an obligation to contribute to the same multiemployer pension plan and are sold or liquidated in a series of transactions.

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