SECTION 7. TIME FOR ADOPTING

CERTAIN AMENDMENTS RELATING TO SECTION 415

For purposes of § 767(d)(3)(B) of GATT, the date provided by the Secretary for adopting plan amendments reflecting the changes to § 415(b)(2)(E) is the last day of the plan’s remedial amendment period under section 6.04. Moreover, as discussed in section 3.04, § 1449(d) of SBJPA provides that an amendment applying specified GATT changes that was adopted or effective before August 20, 1996, will be disregarded in applying § 767(d)(3)(A) of GATT, as modified by § 1449(a) of SBJPA, if that amendment is repealed by another plan amendment that is adopted no later than August 20, 1997. Pursuant to this revenue procedure, a plan amendment applying the amendments made by § 767 of GATT which was adopted or made effective on or before August 20, 1996, also shall not be taken into account in applying § 767(d)(3)(A) of GATT as amended by § 1449(a) of SBJPA, if the amendment is repealed by another plan amendment that is adopted on or before the last day of the plan’s remedial amendment period under section 6.04. This relief will not fail to be available merely because a plan is not operated in accordance with the repealing amendment prior to the date specified in future guidance. The Service intends to issue additional guidance concerning the GATT and SBJPA changes to the limitations under § 415(b) in the near future.