Transcription of chapter 10-coverage and nondiscrimination
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chapter 10-coverage and nondiscrimination
chapter 10- Coverage and nondiscrimination Page 10-1 Coverage and nondiscrimination chapter 10 Coverage and nondiscrimination Demo 6 By Terry Bates (Atlanta) And John Almquist (Pacific Coast) and Al Reich Reviewers INTERNAL REVENUE SERVICE TAX EXEMPT AND GOVERNMENT ENTITIES Introduction Purpose of chapter Coverage and nondiscrimination has been the subject of major CPE Chapters in 1997 ( chapter 1 Guide to Coverage and Discrimination Issues), 2002 ( chapter 7 Coverage and nondiscrimination with Emphasis on determinations processing) and 2003 ( chapter 1 nondiscrimination detailed review of demonstrations). The understanding of Coverage and nondiscrimination is vital. This chapter contains traditional coverage rules, current updates and an emphasis on Demonstration 6 New Comparability , including the Gateways, and Cross-Testing.
This chapter focuses on the relationship of IRC 410(b) and 401(a)(4) in dealing with Demonstration 6. Overview of Coverage Rules – IRC 410(b) Three basic tests There are three basic tests for satisfying coverage. • The 70% Test (IRC410(b)(1)(A)) • The Ratio percentage test (IRC410(b)(1)(B))
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