Generation 7 Investing in Your Legacy
IRS Position
PRIVATE LETTER RULING 199908006 - click here to view the entire document
The IRS has approved an income deferral plan in a private letter ruling. The plan that was the subject of the ruling had the following terms and features:
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All Tribal Members are Eligible to Voluntarily Participate
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A Written Application to Participate is made by the member
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The Trust Satisfies the Requirement of a Master Trust that are set forth in IRS Revenue Procedure 92-64
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Benefits are Payable to the Member during Lifetime or After Death, Depending on the Election by the Member
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Distributions for hardship are allowed
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Per Capita Payment Savings Plan
IRS Revenue Procedures 2003-14 – Establishes a safe harbor for trusts for minor members
***Tribes are not required to obtain a private letter ruling from the IRS in order to establish a savings plan. A tribe should always engage qualified legal counsel to provide advise and to structure a savings plan



